BAYER ADDYSTON OHIO PLANT - Executive Summary |
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Executive summary for Risk Management Program 1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Bayer Corporation is committed to the principles of Responsible Care which emphasize operating in a safe and environmentally correct manner. Management systems are in place to assure all facilities are complying with these principles. There are Corporate Engineering Standards and Health, Environment and Safety Guidelines which address every aspect of Risk Management from design of intrinsically safe processes and use of layers of protection to incident tracking and program audits. Bayer Corporation is the North American subsidiary of Bayer, AG, which is headquartered in Leverkusen, Germany. Bayer Corporation has its own corporate structure, policies and procedures which are consistent with those of the parent company, but are customized to meet US regulations and standards. Bayer AG has established guidelines for Responsible Care in Environmental Protection and Safety, which includes a Directive for Process and Plant Safety that all Bayer facilities world-wide are expected to follow. It provides guidance for safe process design and operation. In the US, Bayer Corporation is an active member of the Chemical Manufacturer's Association Responsible Care Initiative. Bayer has implemented all six codes of management practice which have been verified in practice by a third party audit. Bayer Corporation has a Corporate Health, Environment and Safety Policy which states that it is the corporation's responsibility to protect the environment and the health and safety of its employees, customers and communities. This is a primary responsibility, of equal importance to any other business objective. This is supported in the corporation's Vision, Values and Beliefs, which emphasize applying technical expertise to advance our business while assuring the safety and protection of our employees, customers, communities and the environment. The Bayer Corporation Addyston facility has implemented all of the corporate Health Environment and Safety Policies and Guidelines through site policies and procedures. These include site Safety and Health Procedures, Emergency Response Procedures, Process Safety Management Procedures, Hazard Communication Procedure and Risk Management Procedure as well as safety plans in the individual production unit Standard Operating Procedures (SOPs). 2. FACILITY DESCRIPTION AND REGULATED SUBSTANCES The facility manufactures plastics and resins. The plastic pellet products are sold to molders for end use in refrigerator and automobile interiors, medical uses, computer housings, health spas, tools, and much more. The resins are sold to primarily to paint manufacturers, where the resins add special qualities to automobile paints. Other resins are used to coat circuit boards and coat aluminum cans to allow printing on the can. Two RMP chemicals are used in the plastics process, acrylonitrile and butadiene. These make up two of the three main chemicals used to make the plastic products. (The third being styrene a non-RMP chemical). Acrylonitrile is a liquid and is received by barge and stored in 2 large tanks (600,000 and 900,000 gallons) prior to being used in smaller tanks and in several plastic manufacturing processes. Butadiene, a flammable chemical, received by rail car, and stored under pressure in a 60,000 gallon tank. All storage tanks have concrete dike floors and walls capable of holding more than the quantity of the material being stored. Multiple processes use these chemicals in various quantities ranging from 2,000 to 15,000 lbs in a process at one time. Acrylonitrile represents the worst case scenario for toxic chemicals. Butadiene is the only flammable RMP chemical and thus represents the worst case flammable scenario. One RMP chemical is used in the Resins process, formaldehyde. Formaldehyde is a toxic liquid received by tank truck in a water solution called formalin, which is 53 % formaldehyde, 6 % methanol (non-RMP chemical) , and 41 % water. The formalin is stored in a 150,000 gallon storage tank that has concrete dike floors and walls capable of holding more than 150,000 gallon. 3A. WORST CASE RELEASE SCENARIOS The worst case scenario for acrylonitrile assumes the following: ' Greatest quantity of acrylonitrile 6,000,000 lbs is release from the largest storage tank over a 10 minute period ' The release is into the concrete dike which reduces the impact of the spill ' The release occurs during worst case weather conditions ' All safety precautions and emergency response at the facility fail The distance to the 35 ppm endpoint for acrylonitrile is 5 miles based on the EPA's off site consequence guidance documents. The worst case scenario for the flammable chemical, butadiene, assume the following: ' Greatest quantity of butadiene 140,000 lbs is instantly released from 1 railroad car. ' The released vapors are ignited and explode. ' All safe ty and emergency response precautions at the facility fail. The distance to the 1 psi overpressure endpoint is 0.43 miles based on the EPA's off site consequence guidance documents. 3B. ALTERNATIVE RELEASE SCENARIOS The alternative case scenario for acrylonitrile assumes the following: ' Emergency vent release or 4,000 lbs from a manufacturing process vessel: ' Typical weather conditions (as provided by EPA) The distance to the 35 ppm endpoint for acrylonitrile is 0.72 miles based on the EPA's off site consequence guidance documents. The alternative case scenario for formaldehyde assumes the following: ' Pipe break while unloading a tank truck releasing 25 gallons over 10-15 minutes. ' Typical weather conditions (as provided by EPA) The distance to the 10 ppm endpoint for formaldehyde is 0.19 miles based on the EPA's off site consequence guidance documents. The alternative case scenario for butadiene assumes the following: ' A gasket in a pipeline fails and releases 850 lbs of but adiene. ' Sensors detect butadiene and operators respond immediately ' The released butadiene vapor is ignited ' Typical weather conditions (as provided by EPA) The distance to the 1 psi overpressure endpoint is 0.076 miles based on the EPA's off site consequence guidance documents. 4. ACCIDENTAL RELEASE PREVENTION PROGRAM This facility is one of a few in Ohio to receive OSHA's (Occupational Safety and Health Administration) highest Safety Award, the VPP STAR. Under the Voluntary Protection Program (VPP) OSHA has recognized this facility as having exceptional safety process, programs, and performance. Here is a list of some of those safe practices: ENGINEERING and DESIGN 7 Detailed operating procedures 7 Special equipment standards 7 Special flanges, piping, valves 7 Remotely operated isolation valves 7 State of the art computerized controls, including alarm systems for early warning of problems 7 Redundant & energy protected controls 7 Control Room protection during emergenc ies 7 Inventory minimized for hazardous materials 7 Continuous improvement of processes & equipment 7 Hazard review for all changes 7 Color coding and labeling of piping & vessels 7 Dikes and curbs to contain spills 7 Emergency tank to contain system upsets 7 Spot ventilation system 7 Continuous process analyzers 7 Production units designed to withstand natural disasters DETECTION 7 Process and storage tank area monitoring for acrylonitrile and butadiene 7 Control room air intake monitoring 7 Portable monitors for leak detection 7 Intense vessel inspection program Internal and external) TRAINING 7 Refresher and safety training for all employees 7 New employee qualification requirements 7 Quarterly emergency response drills 7 Specialized maintenance skills training 7 Worker certification programs 7 Off-site specialized training for emergency response teams INSPECTIONS and SAFETY REVIEWS 7 Incident investigations and reviews 7 Systematic equipment inspection 7 Critical instrument an d pressure relief valve inspections 7 Process Hazard Analyses every 5 years 7 Fugitive emissions monitoring program 7 Regular safety audits of all operating units 7 Tracking system for recommendations 7 Special permits required prior to maintenance work MEDICAL MANAGEMENT 7 Certified EMT's 7 Physician on site 5 days per week 7 Physician's Assistant and nurses on dayturn MITIGATION 7 Release containment equipment and materials at each unit 7 Neutralization and decontamination procedures 7 Fire water monitor guns near process and storage tanks 7 Foam vapor suppression capability EMERGENCY RESPONSE 7 Trained emergency spill response teams 7 Written emergency action plans 7 Fire brigade (9 members) maintained on all shifts 7 Fire brigade 40 hours training each year and special training at Texas A&M Fire School 7 Emergency alarm systems coded to expedite rapid emergency response 7 Contract with Cincinnati Fire Department 7 Coordination with Addyston Emergency Operations Plan, LEPC, an d Hamilton County Emergency Management Agency 7 Contracts with emergency response companies EMPLOYEE PARTICIPATION 7 Annual reviews of operating procedures 7 Bayer employees make up 100% of emergency teams 7 Employees participate on incident investigation teams 7 Union employee safety trainers The worst case scenarios are extremely unlikely events because of these extensive safety precautions in place at this facility. 5. FIVE YEAR ACCIDENT HISTORY There have been no formaldehyde and butadiene accidents, including EPA reportable quantity (RQ) releases in the past 5 years. The EPA RQ for formaldehyde is 100 lbs and butadiene is 10 lbs. There have been 2 accidents involving acrylonitrile in the past five years that meet the EPA definition of "accident" because they had the potential for off site environmental damage. These did not have any significant health impact and are listed in the attached forms. There were an additional 5 accidents that resulted in releasing greater tha n the 100 lbs EPA RQ for acrylonitrile but did not result in any injuries, evacuations, sheltering in place, environmental damage, or health impacts. Thus, these are not listed in the attached forms, but are identified in this executive summary. 6. EMERGENCY RESPONSE PROGRAM This facility has extensive emergency response capabilities and coordinates with outside agencies. Here is a summary of these capabilities. 7 All employees are trained for first level emergency response. 7 We have 9 trained fire brigade members on site 24 hours per day, 365 days per year. 7 We have 3 fire trucks, including foam capability. 7 We coordinate with and have a response contract with the Cincinnati Fire Department. 7 A plant siren sounds for every plant alarm. The alarm is coded to expedite response by the plant fore chief and emergency fire brigade. The alarm is tested weekly. 7 The Mayor and police department are notified on critical fire alarms along with other facilities (Hitchens Elementary an d others) as needed. 7 We conduct quarterly emergency drills. 7 Public can be notified of chemical accidents through civil defense sirens, loud speakers on fire department vehicles or door-to-door notification via the Addyston Emergency Operations Plan. 7 We coordinate with Addyston for Emergency communications. We are currently updating the Addyston EOP and improving emergency communications. 7. PLANS TO IMPROVE SAFETY This facility continues to improve the safety of this facility. Here are the primary methods: 7 Routine Process Hazards Audits are conducted on every operating unit in the plant. Detailed audit recommendations are made to improve the safety of the process. 7 New equipment is designed to the most modern safety standards and generally replaces older equipment. Over 1999-2000 more than $ 60 million in new production will be installed in the facility. 7 Employees continue to provide specific safety suggestions to improve the safety of equipment, procedures, and pr ocesses. Typically more than 500 suggestions are provided each year. 7 The plant is actively working with Addyston and surrounding response agencies to improve communications with emergency responders and the public during chemical emergencies |