Avery Dennison Chemical Division (U.S.) - Executive Summary

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1. Risk Management Policy and Management System 
It is the goal and principle of our business to manage process safety systems as a means to prevent or minimize the consequences of catastrophic releases of process contents.  Effective process safety management will contribute to the prevention of acute process and equipment failures with the consequent prevention of the effects of such failures. 
 
Proper performance of the procedures risk management program is intended to satisfy our commitment of Environmental, Health, and Safety responsibility to the public, our employees, customers and all those who are stakeholders in our business endeavors.  Further, applicable laws and regulations will be satisfied. 
 
The risk management program was integrated into the facility Process Safety Management System.  The goals of this Process Safety Management (PSM) System are achieved through implementation of the procedures outlined in the Chapters of the PSM Manual: 
 
    Chapter 2: Employee Participa 
tion 
    Chapter 3: Operating Procedures 
    Chapter 4: Training 
    Chapter 5: Contractors 
    Chapter 6: Process Safety Review 
    Chapter 7: Mechanical Integrity 
    Chapter 8: Hot Work Permits 
    Chapter 9: Managing Change 
    Chapter 10: Incident Investigation 
    Chapter 11: Emergency Planning and Response 
    Chapter 12: Process Safety Information 
    Chapter 13: Process Hazard Analysis 
    Chapter 14: Compliance Audits 
 
The Process Safety Management (PSM) Council under the Direction of the Process Safety Management Coordinator is responsible for the overall management of this manual.  The PSM Coordinator (i.e., Manager of Engineering and EHS) is responsible for ensuring implementation of the procedures outlined in this manual.  The Division General Manager and the Division Vice Presedent & General Manager are responsible for ensuring that adequate resources are available to implement the procedures outlined in this manual.  The Manager of Product Stewardship is res 
ponsible for inspecting the PSM Management System annually. 
 
Employee representatives from operations and maintenance will participate in all aspects of the PSM Management System as defined in each chapter. 
 
PSM Council Members: 
 
        - PSM Coordinator (Manager, Engineering) 
        - Plant General Manager 
        - Plant Production Manager 
        - Senior Environmental Engineer 
        - Division Manager of Product Stewardship 
        - Shift Leaders (3) or Designates 
 
2. Facility Description 
Avery Dennison Chemical Division manufactures pressure-sensitive adhesives that are used in label and tape applications.  Some interesting uses of our adhesives are for self-adhesive postage stamps, battery tester labels, and Band-Aid brand adhesive bandages.  The facility employs approximately 65 employees.  The facility prouduces adhesives through batch polymerization of monomers in both water-based or solvent-based systems.  An important chemical used in this process is vinyl acetate 
which is regulated by the Risk Management Program regulation.  Vinyl acetate is stored in one storage tank at the facility (maximum 84,000 pounds) and is used in all reactor systems at the facility.  Vinyl acetate is the only chemical at the facility subject to the Risk Management Program regulation. 
 
3. Worst-Case Scenario and Alternative Release Scenarios 
It is unlikely the scenarios described in this document will occur, EPA regulation defines worst-case and alternative scenarios without regard to their likelihood.  To limit the potential for accident, vinyl acetate is always shipped containing a polymerization inhibitor.  Properly inhibited, vinyl acetate is stable under recommended storage conditions.  At this facility, vinyl acetate is stored out of direct sunlight under cover in a diked tank.  The tank is positioned on electronic scales and any potential leak can be visually observed.  The piping system is double walled with interstitial monitoring.  The loading area is also co 
nstructed to allow for collection and containment of any possible release during transfer operations.  The storage, handling, and use of this chemical at the facility greatly limits the potential for accidental release. 
 
The facility worst-case scenario and alternative scenarios were presented to the Local Emergency Planning Committee (LEPC) in March 1998.  This information was also available to the public during an open house the facility hosted for the community in September 1998. 
 
WORST CASE SCENARIO 
The worst-case scenario for vinyl acetate involves a runaway reaction (self-polymerization) in the storage tank.  Written operating procedures and a high-level alarm limit the quantity of vinyl acetate in the storage tank to 84,000 pounds.  In a runaway reaction the vinyl acetate will polymerize (converted to a solid material that is no longer vinyl acetate) and only a fraction of the total vinyl acetate will be released.  The worst-case scenario results in an estimated release of 17,00 
0 pounds vinyl acetate and a distance to endpoint of 0.43 mile.  It is important to note that the local emergency planning committee (LEPC) has long used a distance of 0.5 mile for emergency planning for this facility.  
 
ALTERNATIVE SCENARIO 1 
This scenario involves the failure of the transfer hose during unloading of a 6,000 gallon tank truck delivery.  The entire contents will be spilled, but the liquid will be contained with a concrete spill containment.  The liquid vinyl acetate will evaporate at 100 pounds per minute and result in a distance to endpoint of 0.16 mile.  The scenario did not account for emergency response actions by trained facility personnel such as stopping the liquid release and using vapor suppression foam (AFFF) and spill removal to mitigate release to the air.  Facility personnel are trained to respond to such emergencies. 
 
ALTERNATIVE SCENARIO 2 
This scenario involves a runaway reaction in a 6,000 gallon reactor resulting in a release of 4,400 pounds vinyl ace 
tate based on the following assumptions: 50,000 pound batch, 44% of batch is vinyl acetate, 75% of batch is polymerized, and 80% of the unreacted vinyl acetate is released from the reactor. The resulting distance to endpoint is 0.08 mile. 
 
ALTERNATIVE SCENARIO 3 
This scenario involves the rupture of the storage tank resulting in a spill of 84,000 pounds.  The liquid vinyl acetate will be contained in a dike that surrounds the storage tank and this will limit evaporation to 6 pounds per minute.  The resulting distance to endpoint is 0.11 mile.  The scenario did not account for emergency response actions by trained facility personnel such as spill removal to mitigate release to the air.  Facility personnel are trained to respond to such emergencies. 
 
4. General Accidental Release Prevention Program 
The facility complies with the requirements of the OSHA Process Safety Management (PSM) rule.  An outline of the facility program is listed in section 1 of this summary.  
 
5. Five-year Acciden 
t History 
The facility has had no accidental releases of vinyl acetate in the last five years.  Further, there have been no off-site accidental releases of vinyl acetate in the history of the facility which dates back to 1972. 
 
6. Emergency Response Program 
The facility maintains a written emergency response plan and conducts regular drills and training for facility response personnel.  Presently the response team has 11 members trained to the haz-mat technician level.  A full inventory of emergency equipment is maintained at the facility.  The facility plans are coordinated with the emergency response plans of the Local Emergency Planning Committee (LEPC), the local fire department, and the county hazardous materials response team. 
 
7. Planned Changes to Improve Safety 
The facility follows a policy of continuous improvement in the area of risk management and process safety management.
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