ZEON CHEMICALS L.P. - Executive Summary |
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EXECUTIVE SUMMARY 1. Accidental release prevention and emergency response policies Zeon Chemicals L.P. is committed to the safety and health protection of our employees, our customers, our neighbors, and others that may be affected by our products or activities. Through participation by all employees, we will provide a safe work place at our sites, in addition to designing and operating our facilities for minimum adverse impact on public health and the environment. We will produce and sell only products that can be manufactured, used and disposed of safely. We will promptly communicate to affected persons the known hazards of our products and activities, and the methods necessary for safe handling and health protection. The foundation of our Health & Safety Program is full compliance with all accepted standards, applicable laws, regulations, and corporate policy. It is the responsibility of all employees to assure that their actions are consistent with the policy at all ti mes. 2. The stationary source and regulated substances handled Zeon Chemicals, Kentucky Plant performs emulsion polymerization on a commercial scale. The major steps in the process include polymerization into a latex emulsion, recovery of unreacted monomer, coagulation of the latex into a wet crumb, and then drying into a final product. In practice, latex is usually accumulated after recovery in storage tanks where it is sampled and tested before "finishing" to a dry product. As a result, a description of the manufacturing of nitrile rubber can be conveniently divided into two areas: Polymerization and Finishing. In a batch process, raw materials are charged independently to each reactor, and the polymerization proceeds to the desired end point in each reactor where it is either stopped or the contents of the reactor transferred to a "blowdown" tank and stopped. The process of polymerization is closely monitored to follow the conversion of monomer to polymer. The conversion i s important for two reasons: Some recipes call for additions of ingredients at specific points during polymerization, and all recipes have specific final conversion target at which time polymerizations must be stopped so that the desired product properties are achieved. Conversion is determined by a total solids method in which the difference in weight before and after drying of a latex sample (to remove water and volatiles) allows the conversion of monomer into polymer to be calculated form the data contained in the recipe. After manufacturing a polymer in latex form and recovery of the unreacted monomer, it is collected in large tanks for further processing to a dry rubber form. The standard finishing process involves addition of a stabilizer to the latex, coagulation of the latex to form a slurry of rubber crumb in water, washing of the wet material, and de-watering and drying to a finished product. Once the latex is coagulated, the resultant slurry is process across a dewater ing screen and sent to a washing tank or tanks. The purpose is to remove water-soluble solids by the addition of fresh water. Whether this is carried out in one tank or in two steps in series, water is usually recycled, and screens are utilized for separating the wet rubber crumb from the free water. It is common for the pH in the wash tank(s) to be controlled using sulfuric acid or sodium hydroxide. The tanks are diked to minimize unusual discharges to the environment. The final operation in the washing process is to mechanically dewater the crumb. These are commonly extruder presses in which the screw forces the wet material through a restriction, and which have a slotted barrel to allow free water to drain away. After dewatering the crumb is fed to the drying process, which is usually accomplished in a continuous tunnel dryer. The crumb is spread on a perforated stainless steel bed, through which hot air passes to evaporate the remaining water. The regulated substances hand led at this facility are: Anhydrous Ammonia, used as a refrigerant for temperature control in the polymerization area. The maximum amount of Anhydrous Ammonia that can be stored at this plant is 45,000 lbs. Acrylonitrile, used as a monomer and basic raw material in the production of Nitrile Rubber. The maximum amount of Acrylonitrile that can be stored at this site is 102,000 gallons. 1,3-Butadiene, used as a monomer and basic raw material in the production of Nitrile Rubber. The maximum amount of 1,3-Butadiene that can be stored at this site is 1,500,000 lbs. 3. The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distance for each reported scenario 7 Worst-Case Scenario Regulated Toxic Chemicals The Worst Case Scenario for the toxic chemical on our site involves the rupture of a large receiver in Anhydrous Ammonia service, releasing 45,000 lbs. of liquid Anhydrous Ammonia in 10 minutes. The release is uncontained and by definition none of our safety systems mitigate the release. The substance will travel off-site before dispersing enough to no longer pose a hazard to the community. The release would affect public receptors. Worst-Case Scenario Regulated Flammable Chemicals The Worst Case Scenario for the flammable chemicals on our site involves the rupture of a 1,3-Butadiene sphere; releasing 452,400 lbs. of liquid Butadiene in 10 minutes. The substance would ignite causing a vapor cloud explosion resulting in a 1 pound over pressure that will impact our near neighbors. The release would affect public receptors. 7 Alternate-Case Scenario Regulated Toxic Chemicals The Zeon Chemicals, Kentucky Plant has two Alternative Release Scenarios, one for each of the following EPA listed toxic chemicals: Anhydrous Ammonia and Acrylonitrile. A 1" line breaks at the bottom of the Anhydrous Ammonia receiver tank due to contact by Maintenance or other vehicle; releasing 1930 pounds per minute of liquid Ammonia. The tank is emptied in 5 minutes. The release occurs during the most common weather conditions and the release is uncontained. The substance will travel off-site before dispersing enough to no longer pose a hazard to the community. The release would affect public receptors. The high-level alarm fails while unloading Acrylonitrile from a railcar. The tank overflows for 5 minutes at approximately 200 gallons per minute. The unloading operation is fully attended at all times and the pump can be shut down from a remote location. LEL alarms would detect the leak shutting down the pumps. The release occurs during the most common weather conditions and the release is contained in a dike. The substance could travel off-site before dispersing enough to no longer pose a hazard to the community. The release will affect public receptors. 7 Alternative Release Scenario Flammable Chemicals The Alternative Release Scenario for EPA li sted flammable chemicals on our site involves 1,3-Butadine. A pressure gauge is broken off of the liquid Butadiene unloading line. The liquid flows for 10 minutes before the release is stopped. The unloading system is fully attended during unloading and is monitored by LEL detectors which automatically shuts down the system at elevated LEL levels and a deluge system is also triggered by the LEL detector. The substance would ignite causing a vapor cloud explosion resulting in a 1 pound over pressure that will impact our near neighbors. The release would affect public receptors. 4. General accidental release prevention program and chemical-specific prevention steps Zeon Chemicals, Kentucky Plant has in place a thorough, ongoing program of process safety management (PSM). The program includes procedural and engineered safeguards to prevent catastrophic releases and explosions. Some highlights of our program include: 1) Employee Participation - Employees from all areas of the pl ant are involved in numerous activities to continuously improve plant safety. Employee participation is key in the following areas: safety committees, safety and environmental audits, pre-startup safety reviews, process hazard analysis, training, procedure development and monthly safety meetings. 2) Process Hazard Analysis - Various process hazard analysis techniques are performed to identify and analyze the potential hazards associated with the chemicals and processes we use. Corrective action plans are developed and implemented as part of the analyses and updated a minimum of every five years. 3) Operating Procedures - Operating procedures have been developed for all processes to insure safe operation. Those involved with the manufacturing process are included in the development, training and periodic review of these procedures. Our processes are ISO - 9002 certified and subject to internal audits as well as external auditing every six months. 4) Employee Training - Trainin g programs have been developed and implemented to ensure all affected employees understand the hazards of the chemicals used and the required safe handling procedures. The Plant has established an Operator Certification Program to train, test, and qualify employees involved in operating the chemical processes. All new employees complete the certification program and all affected employees are re-certified a minimum of every three years. 5) Mechanical Integrity - This program was established to insure the integrity of process equipment. Elements of this program include the following: 7 Identification and categorization of equipment and instrumentation 7 Inspections, calibration and tests 7 Establishment of prescribed inspection frequencies 7 Development and application of maintenance procedures 7 Training of maintenance personnel 7 Documentation of calibration, tests and inspection results 6) Pre-Startup Safety Reviews - Safety reviews of new processes, major capital projects, a nd new chemicals are conducted to ensure safe transition from the design into commercial activity. 7) Hot Work Permit - This program manages welding, cutting, brazing and other ignition sources throughout the plant to prevent fires and explosions. 8) Management of Change - This procedure is in place to properly manage and communicate changes involving processes, chemicals, technology, equipment or facilities. 9) Contractors - Contract companies are evaluated to insure they have the appropriate job skills, knowledge, training and certification to perform work safely. All contract personnel must complete a Zeon Chemicals training class prior to entering the facility. Training must be repeated annually. 10) Incident Investigation - Any reportable incidents or near misses involving the release of hazardous material are investigated by a team of skilled plant personnel. These investigations identify corrective actions, evaluate our management systems and are documented and communica ted through a narrative report. These reports are circulated to all Zeon Chemical sites. The corrective actions are tracked by Plant Health and Safety Committee for timely completion. 11) Compliance Audits - Audits of our Process Safety Management System are conducted once every three years. These audits consist of review of documentation, verification of process safety information and inspection of the physical facilities. 5. Five-year Accident History The RMP rule requires each company to include a description of all accidental releases resulting in deaths, injuries, or significant property damage on-site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. The Zeon Chemicals, Kentucky Plant has had no events meeting these criteria. 6. Emergency Response Program The Zeon Chemical, Kentucky Plant has an emergency response plan that is coordinated with the Jefferson County Local Emergency Planning Committee (LE PC), Lake Dreamland Fire Department, Rubbertown Mutual Aid Association, and other local response agencies. Plant personnel are trained annually on the plan and new employees are trained prior to working in a process area. The plan consolidates all of the various federal, state, and local regulatory requirements for emergency response planing. Our plan provides the emergency response drills and activities for effectivity protecting workers, the public and the environment during emergency situations. 7. Planned changes to improve safety Our safety program is integrated into all facets of plant operation and involves the identification and implementation by numerous means to improve safety performance. Safety performance is measured in terms of OSHA recordable incidents and is the criteria by which the plant is evaluated by senior management. It is a basic premise of our safety activities that we can only be successful through employee involvement. A Safety incentive award was created for all full-time employees at the site to encourage their participation. |