Rohm and Haas - Hayward Plant - Executive Summary |
|
EXECUTIVE SUMMARY 1.1 Introduction In a series of rules promulgated between 1994 and 1998, the U.S. Environmental Protection Agency established the Risk Management Program (RMP) under Clean Air Act Section 112(r). The RMP contains a list of toxic and flammable chemicals. Facilities that manage more than a threshold amount of a listed chemical may be subject to the RMP. Covered facilities must assess the risks associated with their management of the listed chemicals and produce a plan to prevent releases and accidents. In order to assist in emergency planning, covered facilities must evaluate "worst case" and "alternative case" scenarios that would result from the release of a listed chemical. Finally, the covered facility must make their risk management program available to the public. This document is part of the Rohm and Haas Hayward Plants RMP communication effort. This document comprises the RMP plan for the Rohm and Haas Company Hayward Plant. The plan contains a d escription of all the procedures and provisions to reduce the likelihood and severity of an RMP regulated substance release or accident. The RMP plan is based upon a complete assessment of the processes, operations, and procedures of the plant and an analysis of potential releases of RMP regulated substances that may occur at the plant and their impacts on the offsite populations. 1.2 Accidental Release Prevention and Emergency Response Policies Rohm and Haas Hayward Plant has a long standing commitment to provide a safe workplace and to prevent accidental releases. This commitment is set forth in Rohm and Haas environmental, health and safety policies: * We will ensure our worldwide operations and products are free from significant risks to the health and safety of our employees, customers, carriers, distributors, the general public, and to the environment. * We will meet or exceed all applicable laws and regulations, participate in voluntary initiatives such as Responsibl e Care. and strive for continual improvement in our Environmental, Health, and Safety performance. * We will provide our employees with a safe workplace and support their efforts to work safely. * We will strive to eliminate or reduce emissions, discharges, and wastes from every stage of our operations. * We will communicate, listen and be responsive to our employees, customers, neighbors, and governments, and we will share information concerning potential hazards resulting from our operations or our products. Rohm and Haas is committed to proactive analysis for hazard identification and mitigation. We have formal programs to verify our facility is being operated in accordance with accepted industry practices, company standards and legal requirements. The types of risk management programs required by the RMP have long been in place at Rohm and Haas Hayward. Safe operation is a plant and company priority, and is reflected in policies as well as everyday activities. We welcome the EPAs RMP initiative and see it as an opportunity to expand dialog with our community and to help us improve our safety performance. 1.3 General Description of the Stationary Source The Rohm and Haas Hayward Plant is a specialty chemical manufacturing facility that produces a variety of non-hazardous water-based polymeric emulsions. This activity is described by SIC code 2821 and NAICS code 325211. Approximately fifty different products are manufactured at the plant using different mixtures of reactants. These products are used by our customers to manufacture water-based paints, floor polishes, adhesives, caulks, and other household and industrial products. The Rohm and Haas facility is located in the city of Hayward, California at 25500 Whitesell Street near the intersection of State Highway 92 and Clawiter. The plant is constructed on a parcel of approximately 33 acres at the corner of Whitesell Street and Breakwater Avenue. The northern portion of the prop erty consists of the raw material and finished product storage areas, the plant Process Building, a warehouse, plant utilities, and the plant office and laboratory. The southern portion of the property is undeveloped, with the exception of approximately 3 acres that are leased to Trimac Transportation Services. Trimac operates a dedicated truck terminal exclusively for Rohm and Haas products. Railroad spurs border the eastern and northern edges of the property and a series of treated wastewater sand filters is located at the northwest corner of the property. The polymeric emulsions are produced in two parallel process units. All of the products are manufactured in batch operations. The major raw materials used are monomers, and are received by railcar, tank truck or deck tank. Each of these major raw materials is stored in a dedicated tank with a dedicated pump that is used to unload the railcar, tank truck or deck tank, and to feed the raw material to the process. Once ra w materials are transferred to the Process Building, they are typically pumped to either a mix tank for preliminary mixing with other raw materials and additives, or directly into an emulsion tank where they are mixed with additives. From there, the emulsion mixture is sent to the reactor where the catalyst and activators are added to initiate the reaction. When the reaction is essentially complete, the emulsion goes to drain tanks where additives may be introduced and the pH of the emulsion is adjusted. Bactericides are also added to prevent bacterial growth and resulting product degradation. The emulsion is then pumped through filters into the product storage tanks. The products are shipped out of the facility by tank truck, railcar, or in drums. The finished product leaving the plant is non-hazardous. 1.4 RMP Regulated Substances The RMP regulated substances in use at the Rohm and Haas Hayward Plant are acrylonitrile and vinyl acetate, which are on the RMP list of tox ic substances. Acrylonitrile is transported to the plant in 5,000-gallon deck tanks. It is off-loaded from the deck tank via dedicated transfer lines into a 20,000-gallon aboveground storage tank. Vinyl acetate is delivered to the facility in 20,000-gallon railcars or 5,000-gallon tank trucks. The vinyl acetate is transferred from railcar or tank truck via dedicated transfer lines into a 35,000-gallon aboveground storage tank. Both tanks are surrounded by and protected by an extensive fire control and vapor suppression system. Process vessels that use acrylonitrile and vinyl acetate in the manufacture of emulsions are mechanically and electronically monitored and alarmed to notify process personnel of potentially unusual pressures and temperatures. Process feed rates are controlled automatically to manage the reaction, and standard operating procedures are in place to safely manage the chemicals, the reactions, and any unusual events. Operators are rigorously trained, upd ated and tested on the standard operating procedures. 1.4 Offsite Consequence Analysis Results Releases of acrylonitrile and vinyl acetate from the Rohm and Haas Hayward Plant have potential off-site consequences. The RMP rule provides detailed requirements that define a worst case scenario as that release which is estimated to travel the greatest distance in any direction under worst case weather conditions, with only passive mitigation systems in effect. EPA notes that the worst case scenario is designed principally to support a dialogue between the source and the community on release prevention, and not to serve as the sole or primary basis for emergency planning. Based on previous Plant history, in addition to the several layers of protection in place, this worst case scenario is highly unlikely to actually occur. The Rohm and Haas Hayward Plant worst case scenario assumes a railcar rupture and the instantaneous release of 180,000 pounds of vinyl acetate onto dry soil with no containment dike. Computer modeling indicates such a release would have offsite impacts. This situation is extremely unlikely to actually occur, as the railcar has no bottom outlets; is an insulated, pressure-rated car equipped with tank head puncture-resistance and double-shelf couplers. It is owned by, leased to, and maintained by a third party per DOT requirements. The railcar location is in close proximity to a sewer drain which affords diversion of a portion of the spill to a catch basin. Plant emergency response capabilities, as later detailed, are extensive. The equipment design and Plant safety systems make such a release very unlikely. The RMP rule also defines alternative release scenarios. Unlike worst case scenarios, the alternative release scenario can be limited by active mitigation and safeguards, such as alarms, automatic shutdowns, and operator interventions. According to EPA, the alternative release scenario is a more useful communication tool for the public and first responders for emergency response preparedness and planning. The alternative case scenarios for the Plant were chosen after review of the Plant spill history, process hazard analyses, and discussions regarding potential scenarios with knowledgeable and experienced operating department personnel. Selection drew heavily on the previously developed Risk Management and Prevention Program (RMPP) Plan required by the City of Hayward. The identified scenarios are more credible than the worst case scenario, but remain unlikely due to the design of the equipment and training of our employees. The alternative case scenario chosen for acrylonitrile is a break in the four-inch transfer line while pumping acrylonitrile from the storage tank into the process building. The scenario assumes that proper response would limit the quantity spilled to 18,680 pounds, and that the material would be released during slightly unstable weather conditions and moderate wind speed. A sp ill-control trenching system further limits the exposed surface area of the pool that would result and reduces the release rate to the atmosphere. Computer modeling indicates that the effects from such a release would extend just beyond the Plant boundaries. A similar alternative case scenario of a break in the four-inch transfer line was chosen for vinyl acetate. The scenario assumes that proper response would limit the quantity released to 21,720 pounds, and that the material would be released during slightly unstable weather conditions and moderate wind speed. Again, the spill-control trenching system limits the exposed surface area of the pool that would result and reduces the release rate to the atmosphere. Computer modeling indicates that the effects from such a release would also extend just beyond the Plant boundaries. 1.6 Rohm and Haas Hayward Plant Accidental Release Prevention Program and Chemical-specific Prevention Steps The Rohm and Haas Hayward Plant is fully c ommitted to maintaining a safe workplace. We prevent accidents by taking measures to create and maintain safe conditions in all aspects of our operations including design, operations, and handling. Examples of our safety protection measures include: * Redundant safety systems and instrumentation * Automatic shutdown devices that are triggered if critical safety equipment malfunctions * Secondary containment for storage tanks * Alarm systems and automatic shutdown devices for critical control parameters * Pressure relief devices to prevent overpressurization * Fire protection and vapor suppression systems * Comprehensive written procedures and training programs * Highly trained and experienced operators * Operator surveillance of unloading operations * Permit system to control work in hazardous areas * Preventative maintenance program for equipment * Work preplanning * Controlled entry to Plant site * Environment, Health, and Safety (EHS) reviews for managing change in new and existing processes * Rigorous program for the prevention of potential Y2K computer problems; Y2K contingency plan in place Plant prevention programs are designed in accordance with the OSHA PSM and EPA RMP standards. Additionally, the Plant is required to comply with safety standards developed by the Rohm and Haas Company Corporate Safety Department which, in some cases, are more stringent than OSHA general safety standards. 1.7 Summary of the Five-year Accident History There have been no accidental releases of acrylonitrile or vinyl acetate at the Rohm and Haas Hayward Plant that resulted in deaths, injuries or significant property damage on site, or known offsite death, injuries, evacuations, sheltering in place, property damage or environmental damage in the past five years. 1.8 Summary of the Emergency Response Program In the unusual event that the written procedures, personnel training programs and physical safeguards in place at this facility are unsuccessful i n preventing an accidental release of hazardous chemicals, the Rohm and Haas Hayward Plant has established a comprehensive Emergency Procedures Manual for responding to a release in a safe and organized manner. The Rohm and Haas emergency response plan is based upon the requirements of Rohm and Haas Corporate Standards and was developed in conjunction with the City of Hayward Fire Department. The plan has been designed to meet the requirements of all relevant regulations requiring emergency response plans, and is intended to prevent and mitigate the consequences of a hazardous material spill, protect the well-being of Rohm and Haas employees, the surrounding community, and the environment, and serve as a reference to responders in the event of an emergency. Copies of the Plant response plan have been provided to the City of Hayward Fire Department. This plan provides the requirements for evacuation of the facility; notification of emergency responders, agency contacts and industria l neighbors; emergency first aid or medical treatment for human exposure; coordination of the in-house Incident Command System; use of personal protective equipment; response to specific events (including external events such as earthquakes); and reporting and notification procedures. Rohm and Haas personnel are trained on and familiar with these procedures in order to allow the facility to respond safely and properly to accidental chemical releases. Numerous facility personnel have been trained as on-site incident commanders assigned the responsibility of coordinating the Plant response to any incident which may occur including communicating response needs with the local Fire Department responders. An incident commander is on duty at the Plant 24 hours per day. The Plant Emergency Response Team annually conducts 20 hands-on drills, including quarterly testing of Plantwide emergency alarm systems, an annual Plant evacuation drill, and actual response to Plant emergency scenarios . All Plant employees are trained on the relevant aspects of the emergency response plan. Rohm and Haas has participated in City of Hayward Disaster Exercises and makes the plant and its equipment available to local emergency responders for training exercises. Plant personnel are actively involved in the local Community Awareness and Emergency Response group. 1.9 Planned Changes to Improve Safety It is our belief that effective environmental, health, and safety systems must be continually improved. We constantly strive to recognize areas for improvement and implement the changes necessary to achieve our goals. As a member of the Chemical Manufacturers Association, we have pledged under Responsible Care. to an on-going process safety program that includes measurement of performance, audits and implementation of corrective action. We have developed and put into place sufficient layers of protection to prevent escalation from a single failure to a catastrophic event, and are continually reducing the potential for a worst-case scenario or any kind of accident. |