StanChem, Inc. - Executive Summary
EXECUTIVE SUMMARY: |
Accidental release prevention and
emergency response policies at StanChem
It is the policy of StanChem, Inc. to handle all process chemicals, raw materials, in-process materials, waste materials and finished products in a manner that is protective of the environment, and the health and safety of StanChem employees and the public. With respect to the community outside of StanChem, StanChem is also committed to communicating with and maintaining an awareness by all concerned persons regarding the Companys commitment to environmental, health and safety principles.
The Company holds each of its employees responsible and accountable for compliance with these policies.
The facility and the regulated substances handled
StanChem has three divisions:
1) The Specialty Coating division, which manufactures a diverse group of plastisols, specialty adhesives, printing inks, pigmented dispersions and high-performance coatings;
2) The Albi division, which is a pioneer in
the fire-protective coating industry, and continues to be a leading manufacturer of innovative, high-performance fire-retardant and fire-resistant coatings; and
3) The Polymer division, which manufactures a broad line of polymers for a variety of industries including paint, paper, adhesive and building products.
StanChem is currently uses only one regulated substance subject to EPAs Risk Management Program (RMP). That substance is vinyl acetate, a monomer used in the majority of our polymer products. This material is stored on site in two 20,000 gallon tanks. The tanks are equipped with dikes, level indicators, and audible and visible high-level alarms.
The worst-case scenario and alternative release scenario
Pursuant to the RMP regulations and guidance, the worst-case scenario involving vinyl acetate has been identified as the entire contents of a full vinyl acetate storage tank emptying into the dike. It has been conservatively assumed that the product would remain releas
ed for nearly two days. The model used is the EPAs RMP*Comp software. According to the software, the radius of effect is a 0.7 mile radius around StanChem.
The alternative release scenario is a leak in the transfer hose from a vinyl acetate tanker truck. It has been conservatively assumed that a maximum of 5400 lbs. could be released over a 3-hour period in such a scenario. The model used is the EPAs RMP*Comp software. According to the software, the radius of effect is 0.1 miles.
StanChem believes that as a practical matter, the potential for either of these scenarios to occur is extremely small, given the multiple safe guards and controls against such incidents at the facility, and StanChems many years of operation without such incidents.
The general accidental release prevention program and chemical-specific prevention steps
StanChems accidental release prevention program includes numerous safeguards and controls to prevent or limit the effects of an incident such as
the worst-case scenarios discussed above. With regard to unloading of vinyl acetate monomer into the facilitys storage tanks, these safeguards and controls include, but are not limited to: a vapor recovery system to direct monomer vapors back into the tanker truck; an emergency recovery tank under the tanker truck being emptied to trap dripped or spilled monomer; dikes around the tanks; multiple high-level alarms on the tanks; and directing vapors from potential excess pressure in the tank during loading to a "scrubber" treatment system.
Safeguards and controls for pumping of monomer from the storage tanks to pre-emulsion tanks and subsequently to polymerization reactors include: equipment grounding and bonding; automated material delivery and cut-off valves; pressure and temperature monitors and alarms; check valves; a "kill solution" (reaction inhibitor) to stop a polymerization reaction; rupture disks; and treatment of displaced fumes through the scrubber. Other controls fo
r the polymerization process include: automatic and manual shut-offs; back-up pump; and a purge system to promote consistent and complete polymerization.
In addition to, and as a supplement to RMP measures, StanChem maintains and implements numerous material management, reporting, and other requirements pursuant to the Emergency Planning and Community Right-to-Know Act (EPCRA) Title III and Tier II programs, the OSHA Process Safety Management program, annual and biannual waste reporting requirements, and various other state and federal regulations and reporting requirements. Our employees are trained in Chemical Safety and Hygiene, chemical handling, first-responder emergency response, and other training designated by federal and state regulators. StanChem continuously seeks to identify and assess potential ways to reduce waste, increase productivity, and improve protection of the safety and health of its employees and the public.
Five-year accident history
Due to careful plan
ning and the training and diligence of StanChem supervisors and employees, StanChem has had no accidental releases in the past five years.
Emergency Response program
StanChem has coordinated with the local emergency planning committee (LEPC), fire department, police department, area hospital, utility companies, and StanChems emergency response contractor to handle a potential emergency at the facility and related communications to the public. All StanChem personnel have been trained in accordance with federal and state environmental and occupational safety regulations regarding how to respond to a spill, fire, or medical emergency, and how to contact appropriate outside parties.
Planned Changes to Improve Safety
As noted above, StanChem is committed to continuous improvement of its operations and related protections of the environment and the health and safety of its employees and the public. Further measures to these ends that StanChem plans to take in the near future include
upgrades to raw material storage tanks and "refresher" training of StanChem employees regarding materials management