Air Products Polymer, L.P. - Executive Summary |
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1. Accidental release prevention and emergency response policies: Water-based, polyvinyl acetate emulsions are the main product line manufactured at this facility. Vinyl Acetate Monomer in the amounts handled by our facility is considered hazardous by the EPA. It is our policy to adhere to all applicable Federal and State rules and regulations. Air Products manages the safety of the regulated processes by means of operating procedures, equipment testing and inspectiuons, safety devices (e.g. alarms, shutdowns, instrumentation, relief devices) inherent in the design of this facilty and other controls and systems designed to prevent accidental releases of hazardous chemicals. Safe work practices and training of our personnel supplement the inherent safe design of the plant. Our emergency response program is based upon OSHA's HAZWOPER regulations. Our emergency response plan includes procedures for the notification of the local fire authority and other resources so that appropria te measures can be taken by local emergency responders to control accidental releases. This document has been prepared in accordance with the EPA's Risk Management Plan regulation (40 CFR, PArt 68). The substances and processes considered during the preparation of this RMP and the scenarios described were selected based on criteria established in the regulation. 2. The stationary source and regulated substances handled: The primary purpose of this facility is to manufacture water-based emulsions. Water-based paints and adhesives are used in paints, glues and adhesives. Vinyl Acetate Monomer is an active compound in water-based emulsions. The plant manufactures five emulsion products that use Vinyl Acetate Monomer (VAM) as a raw material. VAM is delivered by railcar and stored in a double walled underground storage tank on site. VAM is a regulated substance that is handled at this facility. It is handled in several different situations. The situations coverd by the regula tion are as follows: Toxicity: * Off-loading of 192,000 pounds of VAM from a railcar at ambient conditions * Pipe Leak of 390 pounds of VAM at ambient conditions 3. Worst Case and Alternate Case Release Scenarios (Flammable and Toxics) The "toxic worst-case scenario", as defined by the EPA, is associated with a release of VAM, is the rapid release of 192,000 pounds of VAM at ambient temperature over a 10 minute period, from the railcar in which it is being off loaded. A full railcar inventory is assumed to be released, resulting in a vapor cloud. The maximum distance to the EPA defined endpoint for this worst case does reach public receptors. There are active mitigation in place directed at preventing such a release, but no credit for the active mitigation measures were taken into account in evaluating this worst case scenario. The "toxic alternate-case scenario" as defined by the EPA, is associated with a release ofVAM, is the rapid release of 390 pounds of VAM, at ambient temperatures over a 10 minute period. The entire contents of the pipe is assumed to be released, resulting in a vapor cloud. The maximum distance to the EPA defined endpoint for this alternate case does not reach public or environmental receptors. Although, there are active controls in place directed at preventing such a release and controlling the consequences, no credit for active mitigations were taken into account in evaluating this alternate case scenario. 4. General accidental release prevention program and specific prevention steps: The facility developed prevention program elements based on the Federal EPA's Accidental Release Prevention Plan, the California Accidental Release Prevention Program (CalARP), and OSHA's Process Safety Management (PSM) regulation. This facility was designed and constructed to comply with applicable state and industry codes. 5. Five-year accident history: This facility has had no accidents involving or accidental releases of VAM that res ulted in any deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 6. The emergency response program: The facility's emergency response program is based upon OSHA's HAZWOPER standard. At this site, employees are trained to recognize emergencies and initiate emergency response from outside agencies. They have been trained to OSHA's First Responder Awareness Level. The employees receive annual refresher training in thier roles in the emergency plan. Emergency response activities have also been coordinated with the LA County Fire Department. 7. Planned changes to improve safety: The facility resolves recommendations fro the PHAs and Incident Investigations, some of which may result in modifications to the plant design and operating procedures. |