Keysor-Century Corporation - Executive Summary |
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Executive Summary 1. Accidental Release Prevention and Emergency Response Policies We at Keysor-Century Corporation are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass the manufacture of Polyvinyl chloride (PVC) resins and compounds. We have 2 regulated substances present at our facility. These substances include Vinyl acetate monomer [Acetic acid ethenyl ester] and Vinyl chloride [Ethene, chloro-]. Vinyl acetate monomer is listed as a toxic while Vinyl chloride is listed as a flammable. Both are raw materials u sed to manufacture PVC resin. The maximum inventory of Vinyl chloride is 1,120,000 lbs., while Vinyl acetate monomer is present in a maximum quantity of 202,000 lbs. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release of 131,000 lb. of Vinyl acetate monomer from a storage tank. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 100.12 minutes. The released quantity has been limited to 90% of the maximum capacity of the source by a system o f administrative controls. Passive mitigation systems such as dike(s) are also taken into account to calculate the scenario. These mitigation systems would provide secondary containment. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.43 miles is obtained corresponding to a toxic endpoint of 0.26 mg/L. The alternative release scenario for Vinyl acetate monomer involves a release of 2,337 lb. from a transfer hose. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 31.40 minutes. The release is also assumed to be controlled by absorbent. This active mitigation will serve to contain the pool. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.26 mg/L of Vinyl acetate monomer [Acetic acid ethenyl ester] is 0.10 miles. The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release of 180,000 lb. of Vinyl chloride is released from a railcar. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.34 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 3 flammable substances involves a release that will result in a Vapor Cloud Explosion. The scenario involves the release of 1619.79 lb. of Flam. Mix.: Vinyl chloride [Ethene, chloro-] in minutes. Passive mitigation controls such as dike system(s) are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include deluge system(s). Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.05 miles. 4. The General Accidental R elease Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Keysor-Century Corporation maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is HAZOP. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 3 years. Any findings related to the hazard ana lysis are addressed in a timely manner. The most recent PHA/update was performed on 03/30/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, Keysor-Century Corporation maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Keysor-Century Corporation has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed. Mechanical Integrity Keysor-Century Corporation carries out highly documented maintenance checks on process equipment to en sure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Keysor-Century Corporation to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 04/30/1999. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Keysor-Century Corporation. The most recent review was performed on 02/05/1999. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Keysor-Century Corporation conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 05/19/1999. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Keysor-Century Corporation promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Keysor-Century Corporation truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Keysor-Century Corporation has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Keysor-Century Corporation has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Keysor-Century Corporation carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent change s taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Providing backup pump for the cooling tower is one of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by 7/31/1999. |