AlliedSignal Inc. - Columbia Site - Executive Summary |
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The AlliedSignal Inc. Columbia Site is a manufacturing facility located in Columbia, South Carolina. It is part of the Polymers Business Unit of AlliedSignal Inc.. Headquartered in Morris Township, New Jersey, AlliedSignal is an advanced technology and manufacturing company serving customers worldwide with aerospace and automotive products, chemicals, fibers, plastics and advanced materials. With 1998 sales of approximately $15 billion, the company ranks among the top 100 of the Fortune 500. AlliedSignal has approximately 70,500 employees at 300 facilities in 40 countries. AlliedSignal operates twelve major businesses: Aerospace Equipment Systems, Aerospace Engines, Electronic and Avionic Systems, Aerospace Marketing Sales and Services, Federal Manufacturing and Technologies, Polymers, Specialty Chemicals, Electronic Materials, Consumer Products Group, Turbocharging Systems, Truck Brake Systems and Friction Materials. More information about AlliedSignal may be found at its Web P age: www.AlliedSignal.com. It is the world wide policy of AlliedSignal to design, manufacture and distribute its products and to handle and dispose of materials throughout their life cycle in a manner that protects the environment and safeguards employees, customers, and the public from unacceptable risk. AlliedSignal's complete Health, Safety and Environmental Policy may be found at the AlliedSignal Web Page. The AlliedSignal Columbia Site participates in the Responsible Care program of the Chemical Manufacturers Association. The Community Awareness and Emergency Response Code of Responsible Care brings chemical plants and local communities together through communications and cooperative emergency planning. The Process Safety Code of Responsible Care is designed to prevent fires, explosions, and accidental chemical releases. The code requires safety audits, inspection and maintenance programs, and safety training for employees and contract workers. Facilities are encouraged to listen to the concerns of the community and to consider these concerns when designing and implementing process safety systems. The AlliedSignal Columbia Site endeavers to accomplish this by sponsoring and regularly meeting with an established local Community Advisory Panel. The AlliedSignal Columbia Site is a nylon resin and fiber manufacturing facility that has approximately 900 employees. The products that the facility manufactures are used to make a variety of different types and styles of nylon carpeting, woven and knitted nylon performance fiber products, and a multitude of plastic products from automobile parts to food wrap films. The facility's nylon manufacturing process involves polymerizing a mixture of the raw material caprolactam and various additives. One of the additives used is cyclohexylamine which is on the RMP Rule's list of regulated substances. The AlliedSignal Columbia Site's storage and use of cyclohexylamine is present in more than the Rule's specified threshold quantity of 15,000 lbs., is defined by EPA as a "covered process" and is therefore regulated under the RMP Rule. In accordance with the requirements of the RMP rule, a description of the following seven elements is provided for the AlliedSignal Columbia Site: 1. Accidental release prevention and emergency response policies: It is the policy of the AlliedSignal Columbia Site to operate a safe and environmentally sound facility by identifying and controlling health, safety, or environmental risks related to its operations; by designing its processes to protect people, property and the environment; by conducting and continually reviewing and improving programs for safety, health and environmental excellence; and by establishing processes to assure that all laws and regulations applicable to its operations and products are known and observed. The accidental release prevention and emergency response policy associated specifically with the Plant's use of cyclohexylamine in volves the integration of safety devices and technologies inherent in the design of the process, safe operational procedures and management practices, operator training, the preparation and testing of site emergency response plans, the maintenance of onsite emergency response equipment and a professionally trained Emergency Response Team, coordinating our efforts and resources with local emergency response services, and communicating with the community. 2. The stationary source and regulated substance handled: The AlliedSignal Columbia Site uses cyclohexylamine as an additive in the manufacturing of nylon. It is stored and handled in quantities that exceed the threshold quantity specified in the RMP Rule. The Site's stationary source of cyclohexylamine consists of bulk storage and process distribution equipment located as part of the Carpet Fibers Polymer Department on the eastern side of the Plant site. Cyclohexylamine is purchased from an outside vendor and is delivered to th e Plant via tank truck on an "as needed" basis. The tanker's contents are unloaded by Plant operators into an above ground bulk storage tank identified as VT-902 which is located in an outdoor tank park. The maximum capacity of the bulk storage tank is 54,000 lbs. Cyclohexylamine is pumped from the bulk storage tank through an enclosed piping system into the production areas where it is fed into the nylon polymerization process units. 3. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distance for each reported scenario: The offsite consequence analysis for a "worst-case release scenario" at the Columbia Site's stationary source was performed for the largest single storage vessel for cyclohexylamine which has a maximum holding capacity of 54,000 lbs. The vessel, identified as VT-902, is a vertical, cylindrical steel tank located in an outdoor tank park adjacent to the Site's Carpet Fib ers production facility. The tank sits on a solid concrete base within a concrete walled dike designed to contain the full contents of the vessel should a release occur. The tank's actual operational storage content is maintained at 45,000 lbs. which is intentionally below its maximum design capacity. The parameters used for the worst-case release scenario for the cyclohexylamine source were those defined and pre-set by EPA in the RMP Rule for toxic liquids. In accordance with the Rule, the maximum 54,000 lb. full capacity contents of the vessel were assumed to instantaneously spill from the vessel and form a liquid pool within the surrounding dike. The dike is defined in the RMP as a "passive mitigation system." The methodology recommended in EPA's Offsite Consequence Analysis Guidance document was used to determine the volatilization of the liquid pool into the air as well as the distance traveled by the cyclohexylamine vapors before the concentration of the vapors decreased t o an endpoint concentration of 0.16 milligrams per liter of air. This endpoint concentration was selected by EPA and listed in the RMP Rule specifically for cyclohexylamine. Using the EPA Guidance Document to determine the offsite impact of the Columbia Site's worst-case cyclohexylamine release, it was found that there would be no cyclohexylamine vapor concentrations above the endpoint concentration that would leave the Columbia Site property from such a release. The nearest distance from the bulk cyclohexylamine storage tank, VT-902, to the Plant's property line is 620 feet. As a result of these findings, the AlliedSignal Columbia Site meets the eligibility requirements for Program 1 status under the RMP Rule and is not required to conduct the less severe "alternative release scenario" analysis. 4. The general accidental release prevention program and chemical specific prevention steps: The general accidental release prevention program at the AlliedSignal Columbia Site f or the cyclohexylamine stationary source includes the following elements: a) established process safety management system for oversight and control of the cyclohexylamine process b) development and implementation of accurate procedures for safe operation and maintenance of the process c) an on-going mechanical integrity program that ensures critical process equipment is designed, constructed, and installed in accordance to codes and standards and is also inspected, tested and proactively maintained d) performance of process hazards analyses with prompt resolution of any recommendations e) use of safety shutdown, relief and vent systems, interlocks, dikes and other secondary containment installations, control instrumentation, and process monitoring for early warning and detection f) implementation of procedures designed to review and manage changes to the process g) performance of incidence investigations, process safety compliance audits, and pre-startup safety reviews and h) a thorough area-specific training program for process operators and maintenance personnel. Chemical specific prevention steps include: a) developing an understanding among the operators for the hazardous properties of cyclohexylamine, the process chemistry and safe operational process limits such as temperatures, pressures, and flows b) understanding the consequences of unsafe chemical handling, process deviations and inadvertent mixing of incompatible chemicals c) having knowledge of the requirements, capabilities and limitations of both personal protective and emergency response equipment and maintaining easily accessible inventories of each d) designing the process technology and process equipment based on a thorough understanding of the hazardous properties of cyclohexylamine and e) providing operators with specialized training from the manufacturer of cyclohexylamine regarding its hazards and proper handling procedures. 5. The five year accident history: No accidental releases from the cyclohexylamine stationary source have occurred at the AlliedSignal Columbia Site in the past five years. 6. The emergency response program: The AlliedSignal Columbia Site has an emergency preparedness planning and response program designed to deal with accidental releases and other unplanned events associated with the facility's stationary source involving cyclohexylamine. The Site has a written Emergency Response Plan that addresses various types of contingencies including specific actions for responding to an accidental release of cyclohexylamine. The Plan provides for both internal Site and external community emergency alerting and notification with established call trees with multiple means of communication identified. The Plan addresses emergency health care, inplace sheltering, evacuation, emergency responsibilities, response and control procedures, and emergency equipment. The Plan provides for the implementation of an Incident Command System to di rect and coordinate the Site's response activities. The Plan has been coordinated with the LEPC and with the local Fire District who would direct all offsite community response activities. The AlliedSignal Columbia Site maintains its own professionally trained Emergency Response Team (ERT) which is knowledgeable and prepared to respond to incidents involving accidental releases of cyclohexylamine. The ERT holds annual Plant emergency response drills and exercises that have been conducted jointly with the local Fire District response group. Annual in-house audits of the Site's emergency response system are performed. 7. Planned changes to improve safety: A process hazard analysis of the AlliedSignal Columbia Site's stationary source of cyclohexylamine was completed in November of 1997. As a result of this systematic safety review, several action items were identified and implemented to improve upon the existing safeguards of the covered source and to further reduce the poten tial for accidental release. The process hazard analysis for the cyclohexylamine stationary source will be reviewed and revalidated every five years. |