The Geon Company - Pedricktown, N.J. Facility - Executive Summary

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THE GEON COMPANY, PEDRICKTOWN, NEW JERSEY FACILITY DESCRIPTION  
 
The Geon Company is a leading North America based polymer technology and service company with operations in polyvinyl chloride compounds and other value-added products and services, as well as polyvinyl chloride resins.  Headquartered in Avon Lake, Ohio, Geon and its subsidiaries employ more than 3,300 people and have 28 manufacturing plants worldwide.  The Pedricktown facility manufactures speciality dispersion resins. Dispersion resins are used in a wide array of products including resilient vinyl flooring, vinyl gloves, toys, weather stripping, spray coating, can coatings, carpet backing, adhesives and adhesive bandage strips.  
 
During the last two years, Geon has proactively been discussing the most recent Risk Management Program regulatory requirements with community and county officials.  This activity included educational sessions and tours with emergency response personnel, discussion of regulated materials and 
the prevention programs in place to prevent releases, emergency response capabilities and methods and considerations used to calculate worse-case and alternative release scenarios.  This proactive activity included sharing all of the information with the general community in May 1999.    
 
GEON'S ACCIDENTIAL RELEASE PREVENTION & EMERGENCY RESPONSE POLICY 
 
The Geon Company has a strong commitment to accidental release prevention and emergency response as stated in the Plant Manager's Safety and Health Message, Company Environmental Policy and Company Safety and Health Policy.  Geon has fulfilled this commitment through a long history of outstanding safety performance, including receipt of the New Jersey Governor's Award and numerous industry and company awards for safety and environmental excellence.  Geon has also provided long term leadership in emergency response preparedness for both the Pedricktown community and Salem County. 
 
 
PLANT MANAGER'S SAFETY& HEALTH MESSAGE 
 
The Safety and 
Health of all employees and visitors to the Pedricktown Plant is our first and foremost priority.  Any job that cannot be done safely will not be done.  All employees and visitors are encouraged to use all of the supplied safety procedures, training, and tools to prevent injuries both on and off the job.  All employees and visitors have the "License to be safe" and are authorized to delay the start of any task or job until all of their safety concerns have been satisfied.  With each of us personally responsible for our own safety and well-being, our plant will continue to be successful and viable in the future. 
 
 
COMPANY ENVIRONMENTAL POLICY 
 
It is the policy of the Geon Company to conduct our operations in a manner fully protective of employees, customers, public health and the environment. Implementation of this policy shall be through programs which are proactive in nature and go beyond compliance with applicable laws and regulations. Geon's commitment to the principles of Responsi 
ble Care provides clear guidance for action.   
 
We will conduct ongoing evaluation of our operations and products to identify practical opportunities for continuing reduction of releases and wastes. We are committed to a continued reduction of emissions and permit exceedances, as well as, minimizing the generation of solid and hazardous waste.   
 
Excellence in program leadership and stewardship is a key management responsibility. Insuring that all operations in the company are carried out in accordance with this Policy is the responsibility of each employee. 
 
 
COMPANY SAFETY & HEALTH POLICY 
 
The policy of our Company is to safeguard the health and well-being of each employee and our neighbors. Implementation of this policy shall be through the elimination of accidents and, by establishing through our activities, safety and health management among the highest corporate priorities. This policy applies to all employees and contractors to the Geon Company.   
 
Ensuring the safety of all per 
sonnel is everyone's concern and requires a constant sense of awareness and attention to detail. The development of safety awareness can only come through each person's acceptance of his responsibility for safety in conjunction with adequate job orientation, training, recognition and communication of the hazards associated with each work situation. Everyone must believe that all accidents are either preventable or avoidable. 
 
Effective management of our process safety is critical in maintaining the integrity of our operations. All necessary equipment, tools, technologies, procedures, and training will be provided to assist everyone in operating our processes and performing their jobs safely. At Geon every job and operation must be managed safely.   
 
Safety performance will be a key element of each employee's and contractor's performance evaluation.  Excellence in safety performance is a condition of employment at Geon.   
 
The prevention of accidents while off the job is equally importa 
nt. The same principles at work are also effective in preventing accidents in the home, on the highway and in all other activities. 
 
Working and living safely must be our way of life.  
 
 
REGULATED SUBSTANCES 
 
Geon is regulated under the OSHA Process Safety Management Standard and the New Jersey Department of Environmental Protection (NJDEP) Toxic Catastrophe Prevention Act (TCPA), which regulate the management of process safety.  The OSHA Process Safety Management Standard regulation is designed to protect workers from catastrophic process incidents and the TCPA regulation is designed to protect the public and the environment.  These existing programs exceed the new federal USEPA Risk Management Program requirements in many aspects and have been in place for several years.  Geon is also a member of the Chemical Manufacturer's Association and has complied with the codes of practice it has issued for the chemical industry.   
 
Geon has one regulated flammable substance, Vinyl Chloride CA 
S No. 75-01-4 and one regulated toxic substance, Ammonia (anhydrous) CAS No. 7664-41-7 regulated by OSHA and NJDEP.  Vinyl Chloride is used to manufacture dispersion speciality resins.  It is polymerized (reacted and converted) into polyvinyl chloride (PVC) which is an inert plastic.  This conversion takes place in a closed computerized process using state of the art technology.  The product is then dried, packaged and shipped to customers.  Ammonia is used as a refrigerant to make chilled water.  The chilled water is used to remove heat from the dispersion manufacturing process. 
 
 
RELEASE SCENARIOS 
 
The NJDEP and the USEPA accident prevention regulations require companies to analyze what is defined as a worse-case release scenario.  Companies are also required to analyze an alternative release scenario.   
 
The worse-case scenario is a hypothetical release of the largest quantity of any toxic material or flammable listed under the regulations as determined by USEPA.  The USEPA mandates 
that companies presume the release of the entire quantity of the substance in ten (10) minutes.  Geon could not consider the numerous prevention and emergency response systems, procedures, equipment, controls, and trained employees that are in place as part of this scenario. 
 
The alternative case scenario is a more credible scenario that is closer to a real world incident.  Facilities are allowed to include active safety systems.  Active safety systems include procedures and equipment which are used to contain or minimize the impact of an accidental release.  Examples of active safety systems are detection systems, computer controlled valves, fire protection systems and employee actions. 
 
 
WORST-CASE RELEASE SCENARIO 
 
Geon has one regulated flammable substance: Vinyl Chloride (VCM) CAS No. 75-01-4 
The worse-case scenario assumes the failure of the largest storage tank.  This tank has a capacity of 5,000 gallons; however, written operating procedures and high level alarms prevent more  
than 4,000 gallons from being present at one time.  Failure of this tank would release 4,000 gallons (31,000 pounds) of Vinyl Chloride.  It is assumed that the entire contents are released within ten minutes and find an ignition source.  The result is a vapor cloud explosion.  The distance from the source to its endpoint is 0.22 miles.  For flammables, the endpoint is the level at which a fire or explosion could damage dwelllings or hurt people.  Distance to the endpoint for Vinyl  Chloride was found in Table 9 in the USEPA Offsite Consequence Analysis Guidance.  
 
Geon has one regulated toxic substance: Ammonia (anhydrous) CAS No. 7664-41-7 
The worst case scenario assumes failure of the largest single heat exchanger.  This heat exchanger has a capacity of 1,850 gallons; however, written operating procedures and high level alarms prevent more than 650 gallons from being present at one time. Failure of this heat exchanger would release 650 gallons (3,500 pounds) of ammonia.  It is assume 
d that the entire contents are released within ten minutes.  The distance from the source to its endpoint is 1.2 miles.  For toxic materials, the endpoint is the chemical concentration in the air to which a person can be exposed for up to one hour without serious health effects.  Distance to the endpoint for Ammonia (anhydrous) was found in USEPA's Guidance for Ammonia Refrigeration Exhibit 4-4 and Figure 4-2.   
 
 
ALTERNATIVE RELEASE SCENARIO 
 
Flammable Substance: Vinyl Chloride (VCM) CAS No. 75-01-4 
The alternative release scenario is a gasket leak at a pipe or valve flange connection equivalent to a 1/4" hole.  The leak is isolated within ten minutes.  A leak rate of 80 pounds per minute would result in a release of 800 pounds over ten minutes.  Unconfined vapor travels to the lower flammability limit (LFL). The distance to the endpoint for the LFL is less than 0.06 miles.  Distance to lower flammability limit (LFL) for Vinyl  Chloride was found in Table 20 in the USEPA Offsite Conse 
quence Analysis Guidance.  
 
Toxic Substance: Ammonia (anhydrous) CAS No. 7664-41-7 
The alternative release scenario is a gasket leak at a pipe or valve flange connection or a corrosion hole in piping equivalent to a 1/4" leak.  The leak is isolated within ten minutes.  A leak rate of 100  pounds per minute would result in a release of 1,000 pounds over ten minutes.  The distance to the endpoint is 0.2 miles.   Distance to the endpoint for Ammonia  (anhydrous) was found in USEPA's Guidance for Ammonia Refrigeration Exhibit 4-5 and Figure 4-3. 
 
 
MITIGATION SYSTEMS 
 
There are several tiers or layers of mitigation systems in place at Geon.  First and foremost is The Geon Company Policy and committment to excellence in the areas of Safety, Health and Environmental Compliance.  Geon has built a strong reputation fulfilling this committment at the Federal, State and local level and with its own employees and contractors.  Second are the fourteen key elements of the Geon prevention program.  A 
dherence to these elements is further demonstration of Geon's committment to excellence.  Third are the specific mitigation measurements associated with regulated materials that Geon has in place.  These  include dikes, curbs, impervious containment, detection systems, automatic controls, isolation valves, on site wastewater treatment and back-up systems.  Fourth is the site comprehensive emergency response program discussed below.  Finally, is Geon's committment for continued improvement in all covered process areas.   
 
 
PREVENTION PROGRAM 
 
The Geon Company (Geon) has in place an approved Risk Management Program for Ammonia encompassing prevention elements consistent with the New Jersey Toxic Catastrophe Prevention Act (TCPA) Title 13, 1B-3.  Geon also has an approved plan under the New Jersey Spill Compensation and Control Act (DPCC) (N.J.S.A. 58:10-23.11) for both Ammonia and Vinyl Chloride.  Additionally, Geon has a structured program under the Occupational Safety and Health Admini 
stration (OSHA) Process Safety Management Standard (PSM) for Highly Hazardous Chemicals (29 CFR 1910.119) for Vinyl Chloride.  Vinyl Chloride is also regulated under the OSHA Vinyl Chloride Standard (29CFR 1910.1017) and the USEPA National Emission Standard for Hazardous Air Polutants (40 CFR Part 61 Subpart F 61.60).  The same substances that are regulated under the United States Environmental Protection Agency 40 CFR Part 68 Accidental Release Prevention Requirements: Risk Management Programs (RMP) under the Clean Air Act Section 112(r)(7) are also regulated under one or more of these existing programs and their subsequent regulations.  
 
Geon has implemented the following prevention elements as part of these programs:     
 
1. An Employee Participation policy to regularly consult with employees regarding the development and implementation of prevention program elements and hazard assessments. 
 
2. A comprehensive Process Safety Information program which ensures complete and accurate writt 
en information concerning process chemicals, process technology and process equipment. This information is included in the employee training programs.  
 
3. A Process Hazard Analysis is conducted to identify and analyze the potential hazards associated with the processing or handling of highly hazardous chemicals. 
 
4. An Electrical Classification system to ensure properly designed electrical distribution systems in all chemical process areas. 
 
5. The preparation of written Operating Procedures which describe tasks to be performed, operating conditions to be maintained, data to be recorded, and safety precautions to be taken to ensure safe operation of equipment.  
 
6. Employee Training programs to ensure that all employees involved with chemicals, fully understand the requirements to safely operate each chemical process.  The Geon Company has an "Operator Certification" program in place to train, test and certify all company employees who operate a chemical process.  
 
7. A Contractor pro 
gram to ensure that they have the appropriate job skills, knowledge and certifications to perform the job safely.  
 
8. For new or modified processes, a Pre-Startup Safety review is conducted to ensure a safe transition into the normal operating mode.  
 
9. A Mechancial Integrity /  Preventive Maintenance program designed to continually review and ensure the integrity of all critical operating process equipment, process support utilities and instrumentation. 
 
7 Identification and categorization of equipment and instrumentation  
7 Inspections and tests 
7 Establishment of prescribed inspection frequencies  
7 Development and application of pertinent maintenance procedures  
7 Training of maintenance personnel  
7 Documentation of test and inspection results  
7 Documentation of manufacturer's maintenance recommendations 
 
10. A  Hot Work Permit system to manage welding, cutting, brazing or spark producing operations in process areas. 
 
11. A Management of Change system to manage changes involvin 
g processes, chemicals, technology, equipment or facilities.  
 
12. An Incident Investigation of a chemical release or "near miss" is conducted by a team of experienced individuals familiar with the process.  Recommendations are communicated and implemented as appropriate.  
 
13. A facility Emergency Response program is in place in the event of a chemical release.  This program is drilled internally and with the community emergency response personnel on a regular basis.  An all hazards Emergency Response program is also in place for the surrounding community and the county.  This program is coordinated through the Salem County Office of Emergency Services. 
 
14. Annual Compliance Audits are performed to review all relevant documentation, verify process safety information, inspect the physical facilities and conduct interviews with representative plant personnel. 
 
 
FIVE YEAR ACCIDENT HISTORY 
 
During the past five years the Geon Company has had no chemical releases which created an emergenc 
y situation outside the plant boundaries nor resulted in any deaths, injuries, or significant property damage on site or offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage.  
 
 
EMERGENCY RESPONSE PROGRAM 
 
The Geon Company has in place Emergency Procedures for handling accidental releases of chemicals. A notification system is in place to initiate response to any emergency.  Key personnel are notified by a system of alarms, radios and pagers.  Once this notification system is activated, a series of emergency plans is followed by key personnel who are always present on site.  For example, in the event of a fire, the Emergency Response Team will respond and establish an incident command system sufficient to handle the emergency.  The Emergency Response Team is trained to deal with fires, chemical releases, spills and other emergencies.  The Emergency Response Team conducts regular training sessions and drills for team members.  Some members  
are trained in First Aid/CPR.  Coordinated drills with the Pedricktown and Auburn Fire Departments and the Salem County Office of Emergency Management are conducted annually to ensure good communication and operational effectiveness.  
 
The Geon Company is an active member of the Salem County Hazardous Material Advisory Council.  
 
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
The Geon Company will continue to evaluate the regulated process areas under the New Jersey Toxic Catastrophe Prevention Act, the New Jersey Spill Compensation and Control Act, the Occupational Safety and Health Administration Process Safety Management Standard for Highly Hazardous Chemicals and the United States Environmental Protection Agency Accidental Release Prevention Requirements Risk Management Program to ensure safe operation of its facility.  
 
Geon is proactively involved in several risk reduction activities which include: 
7 Technology Research 
7 State of the Art Review 
7 Best Management Practice 
7 Inventory Reduct 
ion 
7 Computerized Process Automation 
 
Geon will continue to work with the community emergency management coordinator, fire departments, community officials and County Office of Emergency Management to coordinate training, drills and information.
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