CEREX Advanced Fabrics, L.P. - Executive Summary |
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This RMP is submitted by CEREX Advanced Fabrics, L.P. for its nylon nonwoven manufacturing process which uses a regulated substance, anhydrous Hydrogen Chloride (HCl). This nonwoven manufacturing process, has been in continuous operation since January, 1970. The process was originally developed by Monsanto Company in the late '60s and operated by Monsanto until sold to James River Corporation in September, 1985. Since 1985, the ownership of the nylon manufacturing operation has changed from James River to Fiberweb North America, and finally in November, 1994 to CEREX Advanced Fabrics, L.P. (CEREX); a stand alone business partially owned and operated by local Management. During this almost 30 year period of continuous operation, there have been no (zero) accidental releases of HCl that have had any off-site consequences or required any medical treatment of a CEREX employee. This excellent safety record is the result of a proactive safety process that is guided by an overall safety principle to "...create an injury free work environment and preserve the environment in which we live." The safety process utilizes a team oriented, continuous improvement approach that is based on 3 key elements: * Requiring safety planning in the design and implementation of major process upgrades and site projects, * Regularly scheduled training and certification of the HCl system with our employees, the HCl supplier and the local emergency response team, and * Seeking out and upgrading the HCl system with proven technology that reduces the potential for accidental release. The CEREX manufacturing site is located adjacent to the Solutia, Inc. (formerly known as Monsanto Company) Pensacola site. CEREX is an integral part of the Solutia site emergency response system which includes a site wide emergency alarm system, emergency radio communications and first response from Solutia's highly trained industial emergency response team that has the equipment needed to handle HC l tank car emergencies. The CEREX HCl system is registered with the Escambia County Emergency Management and CEREX is actively involved with the Region I Local Emergency Planning Committee through the participation of CEREX's Safety, Health and Environment Manager. The anhydrous HCl is transported to CEREX, and stored, in 20,000 gallon, specially designed tank cars that according to the supplier have never had a catastrophic "burst" failure such as required to be used in the "Worst Case Scenario". These tank cars are insulated, double steel wall, pressure rated vessels that are maintained in excellent condition by the supplier. CEREX requires the supplier to utilize tank cars with 7,000 pound per hour excess flow valves which are significantly less than the 15,000 pounds per hour safety valves considered to the industry standard. CEREX uses one tank car approximately every three (3) months, and reorders when the tank car is estimated to be near empty. This limits the maximum amou nt of HCl on site at any one time to be approximately the same as the full tank car (20,000 gallons or 150,000 pounds). Over the years, CEREX has implemented system upgrades to prevent an accidental HCl release including: * pressure monitoring of tank car each shift and twice a week reporting of the tank car pressure to the supplier ( a requirement for supplier certification), * a "drowning/scrubber" system that can safely reduce tank car pressure without an untreated release to the atmosphere, * installation of new "bellows seal" outlet valves on the tank car to eliminate potential fugitive packing leaks commonly associated with the previous type of valve, * annual operator training and bi-annual emergency response training with the supplier and Solutia emergency response team, and * use of special alloy flexible connection hoses that minimize the potential for hose failures. In addition, CEREX has implemented emergency response systems that are designed to detect a minor leak (before it becomes a major release) and provide the means to mitigate the impact of a release on the surrounding community. These emergency response systems and procedures include: * an HCl vapor detection and alarm system that surrounds the tank car with 6 independent sensors calibrated to trigger an alarm at an HCl concentration of 10 parts per million, * the 7,000 pound per hour excess flow valves installed inside the tank car outlet lines that will positively shut off the flow if activated, * redundant rupture disk and pressure relief valves on both the tank car and the supply pipe system (which would prevent an over pressure "burst" scenario), * a remotely activated "fail safe" emergency block valve that can isolate the supply piping system in the event of a pipe system failure, * a deluge water overspray system that can be used to "knock down" an HCl vapor cloud during a major release, * being an integral part of the site wide Solutia emerge ncy alarm system providing very fast response of the highly trained emergency response team, and * on site emergency response equipment including the "C" kit for containing tank car dome leaks. During the third quarter of 1999, CEREX will be installing emergency block valves at the inlet end of the flexible hoses to provide the capability of isolating the flexible connection hoses in a release. These specially designed valves have already been ordered and are expected to be delivered in July, 1999. As dictated by the requirements of the Risk Mangement Rule, CEREX has developed a "WORST CASE SCENARIO" for the HCl tank car that would release the entire 20,000 gallons of HCl in a 10 minute time frame without any response action or mitigation. In this highly unlikely scenario, the resulting release could impact the community up to 16 miles from CEREX's site. CEREX believes the worst case scenario to be an extremely remote possibility due to the incredible release rate required (o ver 15,000 pounds per minute) which significantly exceeds the evaporation rate for the liquid HCl and the fact that according to the supplier, no HCl tank car has ever "burst open" as would be required in this scenario. The "ALTERNATIVE SCENARIO", which CEREX believes is much more realistic, is the failure of the 1 inch diameter flexible unloading hose. In this scenario, CEREX believes that the release rate would be limited by the 7,000 pound per hour excess flow valve and the maximum length of time for this release would be limited by the time required to activate the on site emergency response team. We believe a 30 minute time frame is more than adquate for the emergency response team to be notified, respond, assess the situation and shut off the manual tank car valves. The total release would be 3,500 pounds and could impact the surrounding community for 0.6 miles. The response time for this scenario will be significantly reduced after installing the emergency block valves on t he flexible hose inlet in 3rd quarter, 1999. |