Air Products Polymers LP - Executive Summary |
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Executive Summary Air Products Polymers, LP Dayton, NJ One RMP covered process is operating at the Air Products Polymers, LP facility in Dayton, NJ. The process involves the manufacture of vinyl acetate-ethylene (VAE) copolymer emulsions. 1. Accidental release prevention and emergency response policies: The plant maintains vinyl acetate monomer and ethylene inventories which exceed the RMP threshold quantity for toxic liquids and flammable gases respectively. It is our policy to adhere to all applicable federal, state, and local rules and regulations as well as our own environmental, health, and safety standards. Air Products Polymers, LP manages the safety of our facilities by designing for safe operation, operating the plant safely, maintaining the plant, and by auditing our operations. Our accident prevention program is based on OSHAs Process Safety Management regulation and our emergency response program is based on OSHAs HAZWOPER regulation. The emergency response plan includes procedures for the request of local fire support through the South Brunswick Township Industrial Mutual Aid Council (SBIMAC), the LEPC, and the South Brunswick Office of Emergency Management so that appropriate measures can be taken by local emergency responders if necessary. Air Products Polymers, LP is committed to continuous improvement in all aspects of safety and environmental performance. Air Products Polymers, LP is a member of the Chemical Manufacturers Association and subscribes to the Responsible Care Program. The Dayton, NJ facility is actively involved with local organizations concerned with the safety of our community and the environment such as SBIMAC and the South Brunswick Township Community Advisory Panel. This document has been prepared in accordance with EPAs Risk Management Plan regulation (40 CFR, Part 68) and New Jerseys Toxic Catastrophe Prevention Act (NJAC 7:31). The substances and processes considered during the preparation of this RMP and th e scenarios described were selected based on criteria established in the regulation. 2. The facility and the regulated substances handled: The facility is located on Corn Road in Middlesex County. To produce water-based VAE copolymer emulsions, vinyl acetate liquid and ethylene vapor are first emulsified in water and then polymerized in reactors. The products, non-hazardous liquids, are shipped by railcar, bulk trucks, or packages to industrial customers for applications such as latex paints, non-woven binders, adhesives, and building products. Vinyl acetate monomer is present on site in a 110,000 gallon storage tank, railcars, piping and the processing unit to maintain continuous and efficient production. Each vinyl acetate railcar holds approximately 195,000 pounds. Ethylene is present onsite in a 52,500 gallon cryogenic liquid storage tank, a vapor storage tank, tank trucks, piping, and the processing unit to maintain continuous and efficient production. 3. The worst case release scenario(s) and the alternative release scenario(s): The worst case scenario (WCS) for an RMP listed toxic liquid at the Dayton, NJ facility, as defined by the EPA, involves the release of vinyl acetate monomer (VAM) from the failure of a railcar containing vinyl acetate monomer. A VAM railcar, which has a theoretical capacity of 195,000 pounds, is the vessel that contains the largest quantity of VAM at our facility in the absence of passive mitigation. The EPA Offsite Consequence Analysis Guide was used to determine that this release would result in offsite impact. The worst case release scenario is highly unlikely due to several factors which include a railcar inspection program to maintain integrity, operator presence in the field to watch for leaks or spills, and lower explosive level (LEL) monitors to detect spills. The WCS for a RMP listed flammable chemical at the Dayton, NJ facility, as defined by the EPA, is a catastrophic failure of one of the liquid ethylene st orage tank, releasing 235,000 pounds of gaseous ethylene which is assumed to form a vapor cloud and ignite resulting in a vapor cloud explosion (VCE). The maximum distance to the EPA-defined end point (1 psi overpressure) for this event would result in offsite impact. Although we have active controls directed at preventing such releases, no credit for active or passive mitigation measures were taken into account in evaluating this WCS. The alternate release scenario (ARS) for VAM at our facility is the failure of a fitting on one of our polymerization reactors during pressurization and the subsequent release of VAM. The EPA Offsite Consequence Analysis Guide was used to determine that this type of incident would result in offsite impact if no active or passive mitigation was used. Even though the EPA allows credit for active mitigation methods, no such credit was taken in order to determine a potential offsite impact. The polymerization reactors are equipped with safety systems i ncluding LEL detection monitors, automated emergency ventilation, and a deluge system. The ARS for ethylene at our facility is the failure of an unloading hose during the transfer of ethylene from tank truck to storage. The EPA Offsite Analysis Guide was used to determine that this type of incident would result in offsite impact if no active or passive mitigation was used. Even though the EPA allows credit for active mitigation methods, no such credit was taken in order to determine potential offsite impact. The tank truck unloading process is monitored by trained operating personnel. Remote shut off switches are readily accessible to manually close the valve on the tank truck. An excess flow valve is in service on the tank truck which is designed and tested to automatically close in the event of large drop in pressure in the unloading line. A hose leak during unloading would likely cause a large drop in pressure and therefore close the excess flow valve. The ethylene unloading area is equipped with LEL detection monitors to detect the presence of flammable gases. 4. The general accidental release prevention program and specific prevention steps: The Dayton, NJ plant is covered as a Program Level 3. Our accident prevention program is based on OSHAs Process Safety Management regulation. Air Products manages the safety of our facility by designing for safe operation, operating the plant safely, maintaining the plant safely, and by auditing our operations. Our facility is designed for safe operation through the use of emergency shutdown systems and alarms, water deluge systems, fail-safe valves, and containment systems for the unlikely case of a liquid leak. Systems and equipment are designed to applicable engineering standards and codes. Safety reviews are conducted for all new installations and modifications to existing processes. Our plant is operated safely by trained and certified operators who follow standard operating procedures with define d safe operating limits. Process safety meetings are held regularly for all operating and maintenance personnel including contractors. Investigations are conducted for incidents. We maintain operational safety through preventive maintenance and equipment inspection programs. We hold contractors to the same high safety training standards as our employees. We implement task observation and accident prevention techniques. We routinely audit our operations for compliance with federal, state, and local regulation. We also have a program to audit the plants performance against corporate environmental and safety standards. 5. Five year accident history: There have been no incidents within the last five years at the Dayton, NJ facility that meet EPA Risk Management Program reporting requirements. 6. The emergency response program: The facilitys emergency response program is based on the OSHA HAZWOPER standard. In the event of an emergency, an incident command structure is esta blished and HAWOPER Operations Level Responders act in a defensive manner. The facility is a member of the South Brunswick Township Industrial Mutual Aid Council (SBIMAC) and coordinates programs and drills with the South Brunswick Office of Emergency Management and SBIMAC members. Plant wide drills are completed annually. 7. Planned changes to improve safety: Process safety is evaluated regularly through conducting operational plant hazard reviews (OPHR) and studying incidents which have occurred within the chemical industry. An OPHR was completed in 1998. Process improvements are being implemented as a result of the OPHR and our ongoing process safety evaluations. |