Creanova, Inc. - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Creanova, Inc. has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. Creanova, Inc. has a nine-point policy guiding the accidental release prevention program. These are: 1) Use applicable design safety codes and standards as the basis for design, construction, operation, and maintenance in our facilities. 2) Evaluate facilities, equipment and processes for safety and health concerns. 3) Use multiple safeguards to provide layers of protection in the design, construction and operation of facilities to prevent a single fa ilure escalating into a catastrophic event. 4) Document the safety and health evaluation. 5) Inspect and evaluate process equipment against the design specifications. 6) Maintain current and complete documentation of the process and equipment throughout the lifetime of the process. 7) Develop a Management of Change procedure to control minor changes to process technology, operation and maintenance that may affect the safety of the process. 8) Review all changes to process equipment, procedures and practices to ensure the continued safety of employees and facilities. 9) Develop inspection and maintenance programs that ensure the continued integrity of facilities. Creanova, Inc. has a nine-point policy guiding the emergency response program. These are: 1) Determine what potential emergency situations could occur, i.e., employee injury, fire, explosion, flood, cold weather, loss of electrical power, gas/chemical release, etc. 2) Develop written procedures for potential emergencies outl ining personnel responsibilities, emergency information and equipment. 3) Assign personnel to the emergency positions or tasks specified in the written procedures. 4) Provide appropriate emergency response equipment and ensure that it is periodically inspected. 5) Train emergency personnel to respond to emergencies in accordance with the written procedures. 6) Periodically conduct simulated emergency drills. 7) Review emergency procedures with all employees at least annually. 8) Review emergency procedures whenever there are significant changes in personnel, operations, or plant layout; or at least annually and update as necessary. 9) Document emergency procedure reviews and updates, including the date of the review. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBS TANCES Creanova, Inc. Mobile Plant is located in the Theodore Industrial Park in Theodore, Alabama on a 1,000 acre site shared with Sivento, Inc. This facility employs 231 personnel. Seven production areas produce 12 products in a continuous production schedule, operating 24 hours per day, 7 days a week. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: ammonia, hydrocyanic acid, propionitrile, and vinyl methyl ether. RELEASE SCENARIOS The worst-case scenario (WCS) associated with substances in Program 3 processes at the site is a catastrophic failure of one railcar containing 75,000 pounds of hydrocyanic acid over a 10-minute period forming a vapor cloud. Administrative procedures and equipment interlocks prevent the railcar from containing over this amount. Although we have numerous controls to prevent such releases and to manage their consequ ences, no credit for passive mitigation measures was taken into account in evaluating this scenario. According to EPA's look-up tables, the release would reach offsite endpoints such as public and environmental receptors. The WCS associated with a release of flammable substances in Program 3 processes at the site is a catastrophic failure of one storage tank containing 67,000 pounds of methyl vinyl ether over a 10-minute period forming a vapor cloud which subsequently explodes. Administrative procedures and equipment interlocks prevent the methyl vinyl ether storage tank from containing over this amount. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this scenario. According to EPA's look-up tables, the 1 psi overpressure boundary from the explosion would not reach offsite and would not reach any public or environmental receptors. The ARS for ammonia is from a hole in a flex hose while transferring ammonia from the storage tank to a weigh tank at operating pressure and ambient temperature. The hole could release of 370 pounds of gas over a 5-minute period. The 5-minute release duration is the approximate time necessary to detect the leak, depressurize the line and deluge the vapors with fire water to control the vapor release. No other mitigation measures were taken into account in evaluating this scenario. This release does not have the potential to reach offsite endpoints above the toxic endpoint defined by EPA. The ARS for hydrogen cyanide is from a hole in the unloading hose during unloading of a railcar to a storage tank. The hole could release of 25 pounds over a 2-minute period. The 2-minute release duration is the approximate time necessary for the excess flow valve on the railcar to activate and stop the release. No other mitigation measures were taken into account in evaluating this scenario. This release has the potential to reach offsite but would not reach any public or environmental receptors. The ARS for propionitrile is from a hole in the unloading hose during the transfer of the material from a 55 gallon drum to the process vessel. The hole could release 360 pounds, which is the full amount of the drum. The spilled material would drain to a water filled sump at the waste water treatment area and thereby mitigate the release rate by approximately 50%. No other mitigation measures were taken into account in evaluating this scenario. This release has the potential to reach offsite but the only public or environmental receptors reached would be adjacent industrial plants. The ARS for methyl vinyl ether is from a hole in circulation piping at the storage tank resulting in a pool of a flammable liquid. The hole could release 4,900 pounds over a 20-minute period. The 20-minute release duration is the approximate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigation measures were taken into account in evaluating this scenario. This release does not have the potential to reach offsite endpoints. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The prevention program used by the facility is consistent with the Occupational, Safety and Health Administration's Process Safety Management Standard. The standard includes management systems elements involving safety information, hazard evaluations, operating procedures, employee training, contractor programs, mechanical integrity, pre-start up safety reviews, incident investigations, safe work practices and emergency response. There are a number of chemical specific prevention steps used at the facility including release detection equipment, release containment, and release control equipment. FIVE-YEAR ACCIDENT HISTORY Creanova, Inc. has an excellent record of accident prevention over the past 5 years. We have no incidents in the last five years that meet the RMP reporting requirements. EM ERGENCY RESPONSE PROGRAM INFORMATION Creanova, Inc. maintains a written emergency response program. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid, medical treatment, evacuation plans, and notification of local emergency response. The overall emergency response program for Creanova, Inc. is coordinated with the Mobile Fire Department and the Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. Creanova, Inc. has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, Creanova, Inc. conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant. PLANNED CHANGES TO IMPROVE SAFETY Creanova, Inc. resolves all findings from process hazards analysis, some of which result in modifications to the process. The following types of changes are planned: increase process controls & modify procedures. |