Xerox Oklahoma City Manufacturing Site - Executive Summary
The Xerox Corporation is committed to the protection of the environment and the health and safety of its employees, customers, and neighbors. This commitment is applied worldwide. The following principles govern all business practices in the design, manufacture, procurement, marketing, distribution, maintenance, reuse/recycling, and disposal of products and related services: |
a.) Protection of the environment and the health and safety of Xerox employees, customers, and neighbors from unacceptable risks takes priority over economic considerations and will not be compromised.
b.) Xerox operations are conducted in a manner that safeguards health, protects the environment, conserves valuable materials and resources, and minimizes risk of asset losses.
c.) Xerox is committed to designing, manufacturing, distributing, and marketing products and processes to optimize resource utilization and minimize environmental impact.
d.) All Xerox operations and products are, at a minimum, in full
compliance with applicable governmental requirements and Xerox standards.
e.) Xerox is dedicated to continuous improvement of its performance in Environment, Health and Safety.
Additional information about the Xerox Corporation commitment to the environment and to health and safety may be found at http://www.xerox.com.
The Xerox Corporation Oklahoma City Manufacturing Site (Xerox/OKC) is a photocopier supplies manufacturing facility engaged in the production of:
7 Dry inks (toner),
7 Active Matrix (AMAT) photoreceptors,
7 Thermoplastic Resins,
7 XP-454 Polymer,
7 Reactive Extrusion (REX) Resin, and
7 Binder Tape.
Depending on production schedules, various operations may operate 24-hours per day and up to 7 days per week.
Toner manufacturing involves the blending/extrusion of thermoplastic resin, carbon black, wax, ferrite and other charge control additives followed by various grinding, sizing, screening, and packaging operations. AMAT photoreceptor manufacturing involves applic
ation of various polymer/photosensitive materials, using chlorinated and non-chlorinated solvents as suspending agents, onto a flexible polyester web. Solvents are removed by drying, captured using a dual-bed carbon adsorption system, reclaimed using low pressure steam stripping, and are reused on-site following distillation. Thermoplastic resin manufacturing involves controlled reaction of monomers to produce low melt point copolymers of styrene/butadiene (808) or styrene/methacrylate (707). Both products are manufactured using water suspension reactions, followed by water removal, air drying, and packaging. XP-454 is a conductive resin which is used as an ingredient in photocopier developer production. In the first process step, a carbon black flushing process occurs using solution polymerization. Waste toluene and methanol are internally recovered and reused as part of the process. Reactive Extrusion (REX) Resin is a cross-linked polyester type resin produced by melt mixing in an
extruder, followed by cooling, crushing and packaging. Binder tape manufacturing involves application of glue to foil backed paper, followed by sizing and packaging operations. These operations are supported by Facilities Engineering which provides:
7 Facilities maintenance,
7 Steam generation and distribution,
7 Tower water generation and distribution,
7 Electrical power distribution,
7 Housekeeping services,
7 Communications systems,
7 Environment, Health, & Safety Support ,
7 Groundwater remediation system operation and maintenance,
7 Emergency response systems,
7 Compressed air generation and distribution, and
7 Chilled water generation and distribution.
Additionally, the Site is supported by the Production Control (PC) organization which provides:
7 Materials shipping and receiving;
7 Internal transfers of raw materials, in-process materials, wastes, and products; and
On a mass basis, the major raw materials used at Xerox/OKC include:
7 Methylene Chloride
7 Methyl Methacrylate
7 1,3 Butadiene
7 Nitric Acid
7 Caustic Solution
7 Carbon Black
The Site utilizes truck loading /unloading only.
Xerox/OKC operates under the following types of permits:
7 Air Permits
7 Boiler Permits
7 Stormwater Permit
7 Sanitary Sewer Permit
7 Groundwater Permit
7 Hazardous Waste Plan (approval)
Xerox/OKC has achieved and is maintaining international certification of its environmental management system in accordance with ISO 14001.
With respect to the 112r Risk Management Program, the 808 Resin Manufacturing Plant is the only regulated portion of Xerox/OKC. Storage of up to 14,500 gallons of 1,3 Butadiene subjects the 808 Resin Plant to regulation under the RMP rules. 1,3 Butadiene is the only hazardous chemical regulated under the 112 r program which is maintained at Xerox/OKC above RMP threshold quantities. 1,3 Butadiene is listed under
112 r for its flammable properties only.
Release modelling was performed as required by the 112r program for 1,3 Butadiene using RMP Comp Version 1.06 which was downloaded from the EPA website. The worst case scenario evaluated release of the entire contents of the tank (14,500 gallons) with a subsequent vapor cloud explosion. Administrative controls over the maximum tank capacity were used (85% of 17,000 = 14,500 gallons); such controls include high level alarms and written operating procedures. The alternative scenario was also evaluated using RMP Comp Version 1.06. The alternative scenario consists of a transfer pump seal failure resulting in a 5 lb/minute release over a 10 minute period resulting in a vapor cloud explosion (Review of historical data indicated that this scenario and quantity represented the "most likely" release scenario). No passive or active mitigation was considered during modelling; however, the tank system is equipped with a water curtain and a deluge system
The Resin Plant is subject to the OSHA Process Safety Management Rule; and, maintains compliance with all chemical accident prevention provisions. In addition, the 1,3 Butadiene storage tank is thoroughly inspected annually, including X-ray evaluation of piping every year and gamma-scan of the tank every three years. All reactors are leak tested with butane, using a portable organic vapor analyzer, after all clean-outs and any readings above 5 ppm require investigation and correction prior to start-up. The Plant is also equipped with a back-up power generator, an uninteruptable power supply for the control system, and an on-line back up control system to virtually eliminate loss of process control.
Xerox/OKC has not experienced any accidents in the past five years which require reporting under the 112r program.
Xerox/OKC implements a Site Emergency Response Program which complies with the following Site Emergency Response Planning Procedure:
5.2. The primary emergency response
coordinator (or their designee) shall call a meeting of all emergency response coordinators for the purpose of reviewing the adequacy of the SERP according the following schedule.
5.2.1. At least once per year,
5.2.2. Following each implementation of the SERP,
5.2.3. Following each emergency response drill,
5.2.4. Prior to start-up of any significant new operation/activity.
5.3. The adequacy of the existing SERP shall be evaluated based on review of the following:
5.3.1. The existing "reasonably foreseeable" emergency scenarios and their associated environmental impacts,
5.3.2. The existing regulatory requirements (legal and other),
5.3.3. Implementation experience(s), and
5.3.4. Written and/or verbal feedback from interested parties.
5.4. Based on the above review, the primary emergency response coordinator (or their designee) shall ensure that the SERP is revised to address each of the following requirements:
5.4.1. Appropriate measures/controls shall be in place to minimize the risk
of having an emergency scenario.
5.4.2. Appropriate measures shall be in place for early detection and identification of emergency scenarios.
5.4.3. Appropriate systems shall be in place for reporting and communicating emergency response information on-site and off-site as appropriate.
5.4.4. Appropriate systems shall be in place to ensure a designated emergency response coordinator is on-site at all times; or, is within reasonable driving distance to the OKC Site and is on-call.
5.4.5. Appropriate procedures shall be in place for evacuation of Site personnel to a safe location.
5.4.6. Appropriate procedures shall be developed which instruct personnel how to properly shut-down equipment during an emergency scenario.
5.4.7. Appropriate equipment and properly trained personnel (Xerox personnel or contractors) shall be readily available (or be on-call) during all shifts to appropriately respond to any "reasonably foreseeable" emergency scenario.
5.4.8. Appropriate systems shall be in pla
ce to isolate, contain, and bring an emergency scenario under control (to the greatest extent possible) within the boundaries of the OKC Site.
5.4.9. Steps shall be outlined which instruct the emergency response coordinator on the appropriate actions to be taken to assess and coordinate response to the "reasonably foreseeable" emergency scenarios (this portion of the SERP shall not exceed 3 written pages, supported with charts, diagrams, checklists, etc.). The instructions shall include a hierarchy of emergency response levels and the criteria for establishing the level of response required.
5.4.10. Appropriate measures, systems, and/or procedures shall be in place to ensure that all regulatory requirements which are applicable to the reasonably foreseeable emergency scenarios would be satisfied.
5.4.11. Appropriate procedures/programs shall be in place to ensure all necessary emergency response equipment is properly inspected, tested, and maintained.
5.4.12. Emergency response roles a
nd responsibilities shall be delineated and communicated to all key personnel.
5.4.13. Site personnel shall be appropriately trained to properly carry out their responsibilities during an emergency response scenario.
5.4.14. Outside agencies and contractors that may be called to respond during and emergency response operation shall be informed of the location and hazards associated with the "reasonably foreseeable" emergency scenarios.
5.4.15. Appropriate procedures are in place for coordinating/directing assistance from external parties.
5.4.16. Appropriate procedures are in place for interacting with media personnel.
5.4.17. All information/documentation which may be necessary during an emergency scenario shall be placed in locations which would be readily accessible during response actions.
5.4.18. Appropriate procedures shall be in place for follow-up investigation and corrective action as necessary to minimize the risk of recurrence.
5.4.19. Appropriate procedures shall be in plac
e for remediating any contaminated structures, equipment, water, soils, etc.; and, for collecting, evaluating, and properly managing the resulting wastes.
5.5. Each Plant/Area shall provide all resources which are necessary to support implementation of the requirements of Section 5.4 within their Plant/Area.
5.6. Each Plant/Area shall establish written procedures for identifying and responding to abnormal operations which do not qualify as an "emergency scenario" but have the potential to result in a significant environmental impact or regulatory non-compliance if not corrected.
5.7. The primary emergency response coordinator shall (or their designee) ensure that a practice exercise involving implementation of the SERP is completed at least once per year.
On-site chemical and medical emergency response teams/equipment are maintained for all shifts; and, the Site maintains a fully equipped chemical emergency response vehicle to ensure adequate capability for initail response activitie
s and emergency coordination.
Although we are confident that our processes minimize the possibility of signifiacnt releases of hazardous chemicals, we are continuously striving for improvements in our health and safety programs. In addition to governmental inspections, Xerox/OKC voluntarily undergoes conformance audits twice per year under the ISO 14001 program and corporate audits at least every 18 months. These audits, in addition to our ongoing inspection programs, ensure that valuable process safety improvements are continuously identified and implemented.