BFGoodrich Performance Materials Akron Plant - Executive Summary |
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THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED The BFGoodrich Performance Materials Plant in Akron is a specialty chemical manufacturing plant located four miles south of Akron's downtown business district on a 57-acre tract surrounded by light industry and residences. We manufacture more than 30 chemical products, 75 percent of which are consumed in the U.S. and the rest are sold on the international market, contributing significantly to the U.S. gross national product. Our products include chemicals used to prolong the life of tires, lubricating oil and electrical insulation, chemicals to toughen plastics used in automobile and fiberglass piping, chemicals to strengthen adhesives, paper and fabrics, chemicals to manufacture automobile gaskets, sandpaper and tapes, and chemicals to make latex gloves for use in the medical profession. We have 170 employees with an annual payroll of $8.5 million, paying about $100,000 in city taxes and $600,000 in county taxes annually. Each year, we buy about $12.5 million in goods and services, mainly from local suppliers, and pay about $2.1 million for utilities and $160,000 for freight services. Our plant uses certain chemicals as raw materials that bring us under the EPA Risk Management Program (RMP) Rule. These are 1,3-butadiene, 2-methylpropene and ethylene, each of which are flammables under the RMP; and ammonia and acrylonitrile, each of which are toxics under the RMP. The types of programs recently required by the RMP to prevent serious accidents and to plan emergency contingencies have long been in place at the BFGoodrich plant. We have long understood the relationship between good safety and good business, as reflected by our exemplary and frequently awarded safety performance. Nevertheless, we welcome the EPA's RMP initiative and see it as an opportunity to continue and expand dialog with our community. THE ACCIDENTAL RELEASE PREVENTION PROGRAM AND EMERGENCY RESPONSE POLICIES AT THE STATIONARY SOURCE It is the policy of the BFGoodrich Akron plant to meet and often exceed all requirements established by applicable safety, health and environmental regulations promulgated by Federal and state agencies. Our safety policies and practices have historically preceded the regulation of such practices under, for example, the OSHA Process Safety Management Standard and the EPA Risk Management Program Rule. Our policy is to maintain at a practical minimum the potential for harm to on-site employees and contractors, the public, and the environment, and to have in place contingency actions, coordinated with local responding agencies, for the unlikely event of a serious accidental chemical release. A related program in which we are participating is a company-wide Y2K effort to ensure that Y2K issues associated with our computer-based systems and those of our suppliers will not impact our current safety achievement. Another safety-related program in which we participate is Responsible Care. under the Chemical Manufacturer's Association, and we are certified under the ISO-9000 international quality standard. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The BFGoodrich plant has in place a thorough, ongoing program of process safety management (PSM). This program calls for implementation and maintenance of procedural and engineered safeguards at the plant to minimize the likelihood of a significant release of a hazardous chemical, and to eliminate or reduce the effects of any release that might occur. We have invested and continue to invest substantial effort and capital in maintaining our strong safety performance. Some recent examples of our investments include: installation of a Gunnite-coated earthen dike around storage tanks to protect the ground against spills, at a cost of $100,000 installation of devices to detect flammable vapor releases before dangerous accumulations could occur, at a cost of $25,000 installation of aut omatic devices that prevent a tank from being accidentally overfilled by shutting off the filling pump if the tank level becomes too high, at a cost of $115,000 We are involved in day-to-day safety-focused activities under our program that includes elements such as: (1) Process Hazard Analyses - we routinely perform and maintain up to date, systematic and thorough studies of our operations to identify what could go wrong, identify means of eliminating or reducing design or procedural weaknesses, and implementing improvements. (2) Process Design - our processes and equipment are designed for safety in accordance with applicable industry standards and best engineering practices. Designs include, as appropriate, automatic emergency shutdown systems, pressure relief devices, ventilation systems, and release sensoring systems. Most of our processes are computer-controlled (with operator back-up) which includes internal checks for abnormal conditions, emergency shutdowns, and alarm system s. Our storage vessels, which contain the greatest inventories of hazardous chemicals, are contained in concrete dikes. (3) Training - our operations and maintenance personnel are trained thoroughly on their job tasks, on safe work practices as they apply to their jobs, and emergency contingency actions, before they may operate or maintain equipment. They also receive refresher training periodically. Our procedures for operating and maintaining processes, general safe work practices, and emergency response, are fully documented and maintained up to date in light of any changes at the plant. (4) Maintenance - Each item of equipment at our plant that is involved in maintaining safety or in responding to an abnormal situation is inspected, tested and/or maintained on a frequency that reflects its service and condition. (5) Management of Change - no change to equipment or procedural practices can take place at the plant without a thorough review of the implications of that change to saf ety. No change must adversely impact the safety built into the design and operations of our processes. Our PSM program is tuned to reflect the specific hazards of the chemicals we use. For example, our operating, maintenance, safe work, and emergency procedures address personal protective equipment appropriate to the chemicals being handled. Also, equipment is selected based on its intended service and chemical exposures, including release detection devices. THE FIVE-YEAR ACCIDENT HISTORY We have had no events at the BFGoodrich Akron plant that would qualify for inclusion in the RMP 5-year accident history. THE EMERGENCY RESPONSE PROGRAM We have in place a written emergency response plan that we coordinate with the Summit County LEPC, the Akron Fire Department, and other local responders. New personnel are trained on the plan, we conduct refresher training annually, and we train on any revisions to the plan. The plan is in compliance with the RMP requirements, as well as other applicable EPA and OSHA requirements. PLANNED CHANGES TO IMPROVE SAFETY Our safety program is ongoing, involving the identification and implementation of numerous means of incremental safety performance. For example, we are currently planning the installation of a spill containment and groundwater protection device at the railcar unloading station at an anticipated cost of $140,000. THE WORST-CASE RELEASE SCENARIOS AND THE ALTERNATIVE RELEASE SCENARIOS The RMP provides a detailed prescription for what should be considered a worst case scenario (WCS). Under that prescription we have identified three WCSs. One is a spontaneous, catastrophic failure of a railcar resulting in an acrylonitrile spill. The others involve catastrophic failure of a vessel containing butadiene or 2-methylpropene, assumed per RMP-specification to result in a vapor cloud explosion. Based on use of the EPA Offsite Consequence Analysis Guidance, each of these scenarios are calculated to have offsite impacts. Mor e credible scenarios, called alternative release scenarios (ARSs), were also analyzed. As required by the RMP Rule, we chose hypothetical ARSs that are severe enough to have effect beyond our fenceline. All selected ARSs are highly unlikely scenarios of the type our process safety management program protects against. In our ARSs, the operator is pumping acrylonitrile or butadiene from a railcar to a storage tank. The operator is hypothesized to violate our procedures and fail to wait in the vicinity of the railcar and storage vessel during unloading. The vessel is overfilled and begins to spill into the storage vessel dike and evaporate. This scenario requires that a highly reliable safeguard fails: the transfer pump that would shut down automatically on detection of a high level in the storage vessel. As the spill occurs from the vessel, the flammable gas sensors alarm and within 5 minutes the transfer pump is turned off. The release is calculated (using EPA Guidance and the ALOHA so ftware model) to have impact beyond our fenceline, reaching our industrial neighbors, but not reaching the general public. The safeguards in place against these scenarios are the pump automatic shutdown (assumed to fail here), the release sensors, ignition source control per NFPA standards, and operator training that would prevent the incident. Another ARS involves a large leak from a pipe that carries anhydrous ammonia. Again, no such major releases have occurred in the history of our plant due to a rigorous piping inspection program. It is assumed to take 5 minutes for the operator to isolate the major leak. The release is calculated using the ALOHA model to disperse beyond our fenceline with the potential to reach public receptors. We expect scenarios such as these ARSs to continue to be highly hypothetical and unlikely due to our ongoing program of process safety. We take pride in our safety programs and safety performance, which have been recognized in recent years by numerous a wards such as those conferred by the Ohio Division of Safety & Hygiene, the Summit County Safety Council, the Society of the Plastics, and the Ohio Chemical Council. |