Rohm and Haas Company - Knoxville Plant - Executive Summary |
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1 Rohm and Haas Company - Knoxville Plant EPA Risk Management Plan Executive Summary Introduction The Rohm and Haas Company Knoxville Plant is a manufacturing facility located in Knoxville, Tennessee. Rohm and Haas first came to Tennessee in 1943 as part of the national defense effort in World War II. In a government-owned Plant, the company began production of Plexiglas acrylic sheet for use in American military aircraft. Following the war, Rohm and Haas purchased the Knoxville facility and expanded its production capabilities to include acrylic polymers. Although no longer a Plexiglas manufacturer, the Rohm and Haas Knoxville Plant continues to provide acrylic polymer products which are used by our customers in the manufacture of laundry detergents, facial creams, diaper wipes, paint, caulk, paper coatings, and fiber filled products. In all phases of its operation, the Plant stresses safety and protection of the environment. We are pleased to provide information on our safety a nd emergency preparedness plans, as well as the systems and training at Rohm and Haas designed to prevent accidental releases. The EPA Risk Management Program In a series of rules promulgated between 1994 and 1998, the U.S. Environmental Protection Agency established the Risk Management Program (RMP) under Clean Air Act Section 112(r). The RMP contains a list of toxic and flammable chemicals. Facilities that manage more than a threshold amount of a listed chemical may be subject to the RMP. Covered facilities must assess the risks associated with their management of the listed chemicals and produce a plan to prevent releases and incidents. In order to assist in emergency planning, covered facilities must evaluate "worst case" and "alternative case" scenarios that would result from the release of a listed chemical. Finally, the covered facility must make their risk management program available to the public. This summary is part of Rohm and Haas Knoxville's communication effort. Regulated Substances Handled The RMP regulated chemicals used by the Plant in the manufacture of acrylic polymers are Acrylonitrile, Aqueous Ammonia (30% Ammonia Gas in Water), and Vinyl Acetate. Each are listed as RMP toxic chemicals. Acrylonitrile and Vinyl Acetate are raw materials that are chemically combined to form acrylic polymers. Aqueous Ammonia is used as a neutralizer to adjust the pH of polymers. Acrylonitrile and Aqueous Ammonia are transported to the Plant in tank trucks and stored in individual unpressurized storage tanks. Vinyl Acetate is transported to the Plant in railcars or tank trucks and stored in two unpressurized storage tanks. Each chemical is transferred through closed piped systems to specific polymer production units for processing. The final polymer products produced at the Plant are non-toxic and non-flammable. Accidental Release Prevention and Emergency Response Policies The Rohm and Haas Company Knoxville Plant has a long standing commitment t o providing a safe workplace and implementation of procedures and practices to prevent accidental releases. This commitment is clearly stated in the following Rohm and Haas Company health and safety principles: 4 We will ensure our worldwide operations and products are free from significant risks to the health and safety of our employees, customers, carriers, distributors, the general public, and to the environment. 4 We will meet or exceed all applicable laws and regulations, participate in voluntary initiatives such as Responsible Carer and strive for continual improvement in our Environmental, Health, and Safety performance. 4 We will provide our employees with a safe workplace and support their efforts to work safely. 4 We will strive to eliminate or reduce emissions, discharges, and wastes from every stage of our operations. 4 We will communicate, listen and be responsive to our employees, customers, neighbors, and governments, and we will sh are information concerning potential hazards resulting from our operations or our products. Under these principles, we maintain emergency response procedures and equipment to minimize hazards to human health or the environment from fires, explosions, or any unplanned release of hazardous materials. Accidental Release Prevention Program and Chemical-Specific Prevention Steps The Rohm and Haas Knoxville Plant is fully committed to maintaining a safe workplace. We prevent accidents by taking measures to create and maintain safe conditions in all aspects of our operations including design, operations, and handling. Examples of our safety protection measures include: 4 Redundant safety systems and instrumentation 4 Automatic shutdown devices that are triggered if critical safety equipment malfunctions 4 Secondary containment for storage tanks 4 Alarm systems and automatic shutdown devices for critical control parameters 4 Pressure relief devices to prevent overpress urization 4 Fire protection systems 4 Comprehensive written procedures and training programs 4 Operator surveillance of unloading operations 4 Permit system to control work in hazardous areas 4 Preventative maintenance program for equipment 4 Work preplanning 4 Controlled entry to Plant site 4 Environment, Health, and Safety (EHS) reviews for new processes and significant changes in existing processes Plant prevention programs are designed in accordance with the OSHA PSM and EPA RMP standards. Additionally, the Plant is required to comply with safety standards developed by the Rohm and Haas Company Corporate Safety Department which, in some cases, are more stringent than OSHA general safety standards. A consistently strong safety performance earned the Plant the Rohm and Haas Company Board of Directors Award for Safety three out of the first five years the award was presented. This award is based on the number of lost time injuries, reportable accidents, a nd overall injuries during a calendar year. Five-Year Accident History The Rohm and Haas Company Knoxville Plant has had no accidental releases of Acrylonitrile, Aqueous Ammonia, or Vinyl Acetate in the past five years which resulted in deaths, injuries, significant on- site property damage, evacuations, sheltering in place, off-site property damage, or environmental damage. Emergency Response Program The facility maintains an up-to-date emergency response plan which is coordinated with the local Fire Department and the Local Emergency Management Agency. The plan has been designed to meet the requirements of all relevant regulations requiring emergency response plans, and is intended to prevent and mitigate the consequences of a hazardous material spill, protect the well-being of Rohm and Haas employees, the surrounding community, and the environment, and serve as a reference to responders in the event of an emergency. Copies of the Plant response plan have been provided to the lo cal Police and Fire Departments, a local hospital, and the local and State Emergency Management Agencies. A trained on-site incident commander is assigned the responsibility of coordinating the Plant response to any incident which may occur including communicating response needs with the local Fire Department responders. An incident commander is on duty at the Plant 24 hours per day. Plantwide emergency evacuation alarm systems are tested quarterly, and Plant evacuation drills are held annually. Fire alarm bells are tested monthly. Furthermore, the Plant regularly holds "table top" exercises to discuss and drill on the proper response to a Plant emergency scenario. All Plant employees are trained on the relevant aspects of the emergency response plan. Worst Case and Alternative Case Release Scenarios The RMP rule provides detailed requirements that define a worst case scenario, namely a release of the entire contents of the largest storage vessel occurring under very stable we ather conditions and at a low wind speed. EPA notes that the worst case scenario is designed principally to support a dialogue between the source and the community on release prevention, and not to serve as the sole or primary basis for emergency planning. Based on previous Plant history, in addition to the several layers of protection in place, these worst case scenarios are highly unlikely to actually occur. The Plant worst case scenario is based on the detailed requirements for worst case scenarios as prescribed by the RMP rule and assumes a release of the entire contents of the Acrylonitrile storage tank. Although the capacity of the tank is 67,100 pounds of Acrylonitrile, high level alarms and Plant inventory control procedures prevent more than 60,000 pounds from being present in the tank. As a result, the worst case scenario assumes the ten minute release of 60,000 pounds of Acrylonitrile. In addition, passive mitigation (i.e., a retention dike) limits the exposed surface a rea of the pool that would result and reduces the release rate to the atmosphere. Computer modeling indicates such a release would have a significant offsite impact. Of course, Plant safety procedures and practices make a such release very unlikely. The RMP rule also defines the alternative release scenario. Unlike worst case scenarios, the alternative release scenario can be limited by active mitigation and safeguards, such as alarms, automatic shutdowns, and operator interventions. According to EPA, the alternative release scenario is a more useful communication tool for the public and first responders for emergency response preparedness and planning. The alternative case scenarios for the Plant were chosen after review of the Plant spill history, process hazard analyses, and discussions regarding potential scenarios with knowledgeable and experienced operating department personnel. The identified scenarios are more credible than the worst case scenario, but remain unlikely du e to the design of the equipment and training of our employees. The alternative case scenario chosen for Acrylonitrile is a leak in the three inch tank truck unloading arm. The scenario assumes that proper spill response would limit the quantity released to 3,000 pounds, and that the material would be released during slightly unstable weather conditions and a light wind speed. A retention dike limits the exposed surface area of the pool that would result and reduces the release rate to the atmosphere. Computer modeling indicates that the effects from such a release would extend slightly beyond the Plant boundaries but should not reach residences. The alternative case chose for Aqueous Ammonia is a one inch drain valve left open in the tank truck unloading line. The scenario assumes that proper spill response would limit the quantity released to 20,000 pounds. The material would be released during slightly unstable weather conditions and a light wind speed. Computer modeling ind icates that the effects from such a release would extend beyond the Plant boundaries. The release could potentially affect nearby commercial areas, but should not reach residences. The alternative case scenario chosen for Vinyl Acetate is a leak in the three inch piping which is used to transfer the material from the storage tank to the manufacturing units. The scenario assumes that proper spill response would limit the quantity released to 5,000 pounds. The material would be released during slightly unstable weather conditions and a light wind speed. Computer modeling indicates that the effects from such a release would extend slightly beyond the Plant boundaries but should not reach residences. Changes to Improve Safety It is our belief that effective environmental, health, and safety systems must be continually improved. We constantly strive to recognize areas for improvement and implement the changes necessary to achieve our goals. Methods used to identify areas for improv ement include: 4 Process hazard analyses for manufacturing processes 4 Internal audits of procedures and Plant inspections 4 Safe behavior sampling 4 Environment, Health, and Safety (EHS) reviews for new processes and significant changes in existing processes In addition, the following are examples of safety improvement opportunities identified and implemented by the Plant for an RMP covered chemical. 4 Installation of retention diking around tank truck unloading area to catch material in the event of a spill 4 Conversion from bottom tank truck unloading to top unloading to reduce the potential for spills 4 Installation of a sealless pump to reduce the likelihood for leaks 4 Installation of a backflow prevention device in unloading piping 4 Restriction of traffic under piping to prevent a collision |