Air Products Polymers, L. P. - Executive Summary |
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1. Accidental release prevention and emergency response policies: The Air Products Polymers, L. P. facility located in Piedmont, South Carolina contains one RMP covered process which is a vinyl acetate polymer emulsions manufacturing plant. The plant maintains greater than 10,000 pounds of vinyl acetate monomer (VAM) to safely and efficiently manufacture polyvinyl acetate copolymer emulsions. In the quantities handled by our facility, vinyl acetate monomer is considered to be hazardous by the EPA. It is our policy to adhere to all applicable federal, state and local rules and regulations as well as our internal EH&S policies and practices. Air Products manages the safety of our facility by designing for a safe operation, operating and maintaining the plant safely and by auditing our operations. Our accident prevention program is based on OSHA's Process Safety Management regulation and our emergency response program is based on OSHA's HazWOPER regulations. Air Products is a member of the Chemical Manufacturing Association and subscribes to the Responsible Care(R) Program. The Piedmont Plant is actively involved in the community through its work with the Piedmont Fire Department, Greenville County LEPC and the Piedmont Community Advisory Panel. 2. The facility description and regulated substance: The polyvinyl acetate copolymer emulsions manufacturing facility is located at 410 Old Pelzer Road, Piedmont, South Carolina. To product polyvinyl acetate copolymer emulsions, vinyl acetate liquid is polymerized with other monomers in reactors to form the emulsion product. The emulsion product is a non-hazardous, water based liquid. The product is shipped via railcars, tank trucks, totes, and drums to industrial customers for the production of paint products, paper coatings and adhesives. A maximum of approximately 330,000 pounds of vinyl acetate monomer is present on site in the storage tank, piping and process vessels. Approximately 386,000 pounds o f vinyl acetate monomer could also be present in railcars on site. 3. The worst care release scenario and the alternative release scenario: The worst case release scenario for the RMP listed material, vinyl acetate monomer, at the Piedmont, South Carolina plant, as defined by the EPA, involves the release of material from the failure of the largest vessel containing vinyl acetate monomer and which has the greatest offsite impact. Due to the fact that our largest vessel, >300,000 pound capacity, is in a containment dike, its outside impact was lessened. A railcar which has a theoretical capacity of 195,000 pounds was selected as the worst case scenario because no diking exists. This increased the extent of offsite impact over the largest vessel scenario. The EPA Offsite Consequence Analysis Guide was used to determine the offsite impact. The worst case release scenario is highly unlikely due to several factors: (1) mechanical intergity programs; (2) operator presence watch ing the unloading operation for leaks and spills; (3) top unloading of the railcar; and (4) a spill containment pan and sump. The alternate case scenario for the the vinyl acetate monomer at the facility is a 2 inch puncture in a railcar. This scenario could result in the release of 15,400 pounds of material. Although there have been no instances of a release of this magnitude at the site, we feel that this scenario would be reasonable for emergency planning purposes. The EPA Offsite Consequence Analysis Guide was used to determine the offsite impact. 4. The general accidental release prevention program and specific prevention steps: The facility's accident release prevention program is based on OSHA's Process Safety Management (PSM) regulation. Due to the congruence between the requirements of PSM and RMP, PSM implementation serves to fulfill the requirement of the RMP prevention program at the facility. All the elements of OSHA's PSM regulation have been implemente d. 5. Five year accident history: There have been no accidents involving or accidential releases of vinyl acetate that resulted in any deaths, injuries, or significant property damage on site, or know offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage. 6. The emergency response program: The facility's emergency response program is based upon OSHA's HazWOPER standard. At this site, employees are trained to recognize emergencies and intiate emergency response from outside agencies. They have been trained to OSHA's First Responder Awareness Level. Employees receive annual refresher training in their role in the emergency plan. Emergency response activities have also been coordinated with the Piedmont Fire Department for awareness on potential hazards and the locations of the material on site. Periodic derills are conducted with agencies to review the effectiveness of our emergency procedures. 7. Planned change to improv e safety: We have no current plants to install new mitigation, control equipment or change to technology. We do constantly strive to improve performance in safety and believe our systems represent the state of the art equipment. Process safety and elements of PSM are evaluated for effectiveness. |