Hercules Incorporated - Brunswick Plant - Executive Summary |
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Facility Description: Established in 1912 (and headquartered in Wilmington, Delaware), Hercules Incorporated is a global manufacturer of chemical specialty products that are used in a variety of home, office and industrial products. Hercules Incorporated purchased the Brunswick Plant in 1920 from the Yaryan Rosin Company. The plant is situated on three hundred and fifty (350) acres within the City of Brunswick. With four hundred and thirty (430) employees, the plant operates around the clock, seven days a week. The Hercules-Brunswick Plant is nearly the only one of its kind in the world today that transforms abandoned pine stumps into industrial chemicals ultimately used in hundreds of consumer products, such as adhesives, sealant, chewing gum, toothpaste, citrus drinks, cleansers, and many other goods. In making these products, the facility uses four (4) chemicals included in the EPA's risk management rule. These chemicals are: carbon disulfide, hydrazine, hydrogen, and trimethylc hlorosilane. Carbon disulfide and hydrazine are raw materials used in the manufacturing of a synthetic resin product. Hydrogen is used to hydrogenate (add hydrogen atoms to) the rosins extracted from the pine stumps. Trimethylchlorosilane is used as a processing aid in the production of polymeric terpene resins. Hydrogen is stored in a bulk storage tank with a maximum capacity of 12,420 pounds. Carbon disulfide, trimethylchlorosilane and hydrazine are handled in portable containers of 2,650, 725 and 440 pounds, respectively. While the number of containers of each chemical stored onsite may vary at any one time, with the maximum number of containers exceeding the RMP threshold quantities, only one container is connected to the processes at a time. Policy: Hercules Incorporated is a member of the Chemical Manufacturers Association and is committed to the principles of Responsible Care.. The Corporate Policy on Safety, Health and Environment states: At Hercules, we manufacture chemica l specialty products. We do so with full commitment to the chemical industry's Responsible Care. initiative. In keeping with this commitment, we are dedicated to providing a safe and healthful environment for our employees, customers, and communities. To do this, we are dedicated to and working toward continuous improvement in our operations to prevent pollution; to reduce risk; and to enhance safety, health, and environmental performance. By incorporating these beliefs and attitudes into the way we do things at Hercules, we take a key step forward in minimizing the environmental impact of our operations, satisfying customer needs, and creating shareholder value. We will adhere to the following basic principles in managing our business worldwide: 7 We will comply with the letter and spirit of all applicable safety, health, and environmental laws, regulations, and corporate guidelines. 7 We will define strategic objectives, develop tactical plans, identify clear accountability, provi de necessary resources, and measure our progress on safety, health, and environmental matters on an ongoing basis. Our planning will consider both business goals and significant safety, health, and environmental aspects of our products and operations. 7 We will evaluate the safety, health, and environmental impacts of new and existing products and operations and will work to reduce the adverse impacts. 7 We will provide for an open dialogue on safety, health, and environmental issues relating to our products and operations with our stakeholders, including shareholders, employees, customers, suppliers, government agencies, and communities. 7 We will work to continually reduce workplace injuries; incidents with the potential for causing property damage, material loss, or interruption of our business; waste; and releases to the environment. 7 We will emphasize product stewardship and advocate its importance to our suppliers, distributors, and customers. Every Hercules employee, world wide, has a role to play. All of us are responsible and accountable for adhering to the letter and spirit of this policy. All of us must incorporate safety, health, and environmental considerations into our daily business activities. It takes a total team effort to truly be a Responsible Care. company. Worst-Case Scenario: Following the process detailed in the EPA's Off-Site Consequence Analysis Guidance, the off-site impacts were determined for each regulated substance utilized at the Hercules-Brunswick Plant. The substance that resulted in the most significant off-site impacts under the worst-case scenario was trimethylchlorosilane. The worst-case scenario for trimethylchlorosilane is the instantaneous release of a 725 pound cylinder. The impact of such a release, using the specified EPA meteorological conditions, would result in a vapor cloud that would reach off-site receptor. No active or passive mitigation efforts were considered under this scenario. Alternative Case Scenari o: The alternate case scenario for trimethylchlorosilane involves the release of half the contents (363 pounds) of a cylinder. Typical meteorological conditions for the Brunswick area were substituted for those specified in the EPA guidance. Such a release would result in minimal off-site impacts, just beyond the Hercules fenceline. Accident Prevention Program: Each of the processes, which uses one or more of the regulated substances, is subject to the OSHA Process Safety Management standard (29 CFR 1910.119) and has a complete process safety management system in place. This includes the use of process hazard analyses to identify and address potential hazards, management of change to control modifications, mechanical integrity procedures for minimizing mechanical failures, detailed operating procedures for process control, operator training for the personnel involved in the process and contractor safety assessments to closely monitor activities by non-Hercules personnel. Five Year Accident History: In the past five years, the Hercules-Brunswick Plant has not had any accidental releases of carbon disulfide, hydrazine, hydrogen, or trimethylchlorosilane that have resulted in on-site injuries or any off-site impacts. Emergency Response Program: The Hercules-Brunswick Plant has an emergency response program in place to minimize on-site, as well as off-site, impacts from the release of any of the regulated substances or any chemical utilized in the plant processes. While significant efforts are practiced to prevent all releases, Hercules is cognizant of the fact that they can and do occur. To prepare to respond to a release, the plant has a very detailed emergency response program in place. The key elements of this emergency response program are: 7 written emergency response plans that provide a written step by step procedure for responding to the various type of emergency situations that may arise (fire, spills, hurricanes, etc) 7 emergency response tea ms that provide twenty four hour, seven day a week responce to spill or releases, fires and confined space entry emergencies. The teams meet and train at least monthly and are manned primarily by employee volunteers. 7 emergency response equipment for the teams to operate effectively. Hercules is continually upgrading or purchasing new emergency response equipment that may be need by the response teams. 7 emergency response drills conducted periodically throughout the year. Each response team practices what they have learned by conducting simulated incidents. This allows them to stay alert, up-to-date on the written plans, how to use the equipment and significantly reduces the amount of time needed to respond in the event of a real emergency. All of the emergency response activities are and will continue to be coordinated with the various local agencies. |