GE Plastics - Ottawa - Executive Summary |
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EXECUTIVE SUMMARY 0.1 INTRODUCTION This Risk Management Plan is part of GE Plastics' continuing commitment to minimize the potential impact from our facility on our workers, our community neighbors, or the environment. It is the stated policy of GE Plastics to safely manage our site operations. In addition, we have prepared contingency plans to be used in the unlikely event that a major accident should occur. The efforts at our Ottawa, IL facility have been recognized by the US Occupational Safety and Health Administration (OSHA), who oversees our programs, as among the best in the nation for worker safety. We believe it is important for all interested parties to have access to information that can help them better understand our business and our facility. If you have any questions about this document, or any other aspect of our company or our plans, please contact our Human Resources Department at (815) 433-7455. 0.2 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Our company is committed to operating safe and environmentally sound chemical and plastics production facilities everywhere we do business. Protection of our neighbors and workers is the highest priority. This ongoing commitment to worker and public safety is demonstrated through resources invested for safe design, operation, and maintenance of our facilities. In order to provide top quality products for our customers, the GE Plastics Ottawa, IL facility uses in its manufacturing process some raw materials that are classified as toxic or flammable. We are committed to comply with governing laws, regulations, and engineering standards as well as systematic assessments to manage and maintain a safe operation. Our operating practices and procedures ensure that numerous controls are implemented to prevent an accidental release of a chemical. However, if a major release does occur, our trained on-site emergency response organization will be activated. This organization includes a fir e brigade as well as medical and chemical emergency response teams. The outstanding programs at the Ottawa facility have earned the OSHA STAR award, presented by the Occupational Safety and Health Administration for exemplary safety management. This is OSHA's highest award for safety performance. Because of this exemplary performance, the OSHA Training Institute has chosen to use the Ottawa plant site six times for Process Safety Management (PSM) training. 0.3 DESCRIPTION OF THE FACILITY AND REGULATED SUBSTANCES The GE Plastics plant is on a 215-acre tract along the Illinois River in Ottawa, IL, about three miles east of Ottawa. It was built in 1967 and currently employs about 425 people in the Illinois River Valley. GE Plastics manufactures engineered thermoplastics, marketed under the trade name CYCOLACR. Our products are used in automotive, medical, electronic, computer, and appliance industries to name a few. In order to ensure quality products, quality service and quality of life, GE has invested more than $85 million in the site since 1989 for expansion, capital improvement, safety and environmental protection. The Ottawa, IL plant uses two chemicals that are regulated under the EPA's Risk Management Program (RMP) rule. These are: acrylonitrile, a regulated toxic substance; and, 1-3 Butadiene, a regulated flammable substance. Acrylonitrile and 1-3 Butadiene are raw materials used to manufacture our products. 0.4 HAZARD ASSESSMENT RESULTS As part of our risk management planning, we have specifically identified the type of event that, should it ever occur, would have the most negative impacts on our workers and our neighbors. This is known as the Worst-Case Scenario (WCS). As defined by EPA, we are required to assume that the numerous engineering and administrative safety controls we have in place to prevent or mitigate such accidents have all failed at once. EPA defines a worst-case scenario as a catastrophic failure, which is an event that essen tially results in the instantaneous release of the contents in the largest single vessel on-site that results in the greatest distance to the EPA-defined level-of-concern. Two types of consequences must be evaluated: a release of an EPA-listed toxic chemical and a release of an EPA-listed flammable chemical. This worst-case scenario would involve the catastrophic failure of a railcar tanker containing acrylonitrile liquid. The quantity of material released is assumed to be 173,000 pounds of acrylonitrile. Under this scenario, the acrylonitrile liquid is assumed to evaporate and the vapors disperse in the direction of the prevailing wind. According to EPA guidelines, exposure to acrylonitrile can occur without serious health effects at levels up to 35 parts per million (0.076 mg per liter) for approximately one hour. A scenario used to meet the Alternative Release Scenario (ARS) requirements of the regulation involves overfilling an acrylonitrile storage tank while transferring mat erial from a railcar. As much as 8,300 pounds acrylonitrile could be released. The secondary containment dike around the storage tank would mitigate the impact of this scenario. The Worst-Case Scenario (WCS) involving flammable materials at the facility involves a catastrophic failure of a butadiene storage tank, resulting in the instantaneous release of up to 3.5 million pounds of butadiene. The scenario assumes butadiene will vaporize and the gas will ignite and result in a vapor cloud explosion. The Alternative Release Scenario (ARS) for all flammable materials involves the partial failure of a pipe connection to a barge containing butadiene at our dock on the Illinois River. This could result in a release of up to 440 pounds of butadiene gas. Since trained and certified personnel continuously attend the butadiene transfer operation, emergency shutoff valves would quickly isolate this leak. 0.5 GENERAL ACCIDENTAL RELEASE PREVENTION / CHEMICAL-SPECIFIC PREVENTION STEPS GE Pl astics has implemented a comprehensive program to prevent accidental releases of highly hazardous chemicals known as Process Safety Management (or PSM). PSM is an integral part of working safely at GE Plastics facilities. PSM ensures that proper safety information is in place; operating procedures are followed; chemical hazards are identified; employees and contractors are trained; and critical equipment is properly inspected and maintained. PSM satisfies the accidental release prevention program requirements of the RMP. Some of the many, specific safety features to prevent a chemical accident include: 7 Railroad tankcars are regulated and inspected under U.S. Department of Transportation regulations that require periodic pressure testing and are built to stringent safety standards that provide protection in the event of a rail accident. 7 Safety instrumentation, high tank level shutoffs, and procedures that reduce the potential for human error which could lead to a storage tank o verfill; 7 Shut-off valves for the butadiene and acrylonitrile storage tanks that can be closed from a remote location, if needed; 7 Secondary containment dikes around storage tanks to contain a spill; 7 Butadiene and acrylonitrile gas sensors to detect and warn of a release in the tank farm and latex operating areas; 7 Local spill containment around acrylonitrile railcars at the unloading station to mitigate the impact of a leak; 7 Acrylonitrile railcar and butadiene unloading operations are continuously attended by Tank Farm Technicians who have had specialized training in US Department Of Transportation (DOT) requirements; 7 An inherently safer process for latex manufacturing. Under this process, the amount of butadiene is controlled such that if a problem were to be detected that required the process to be shutdown, the chemical reaction would immediately cease before an unsafe condition could develop; 7 A computer-controlled Safety Instrumented System (SIS) on the latex manufact uring process to ensure that any deviations from the intended operating conditions are immediately identified and corrected. 7 Backup cooling water systems in the plastic resin manufacturing processes that can be activated both automatically and manually; 7 Backup shutdown systems for the plastic resin manufacturing processes; 7 Extensive safety information about the processes reviewed with employees and contractors; 7 A comprehensive safety review program for all over pressure safety relief devices; 7 Written operating procedures that emphasize safe operating practices and include emergency response actions; 7 Comprehensive employee and contractor safety training programs to promote consistently safe work-practices; 7 Maintenance programs to ensure ongoing equipment reliability - includes equipment testing, inspection and repair; 7 Site-wide piping and electrical standards for the design, installation and repair of equipment; 7 Safety pre-qualification requirements for all cont ractors; 7 A safety procedure to review proposed plant modifications before they are implemented for possible hazards (this is called "Management of Change"); 7 Safety reviews prior to startup of process changes; and, 7 Safety permit procedures that control hazards during special operations such as welding and other maintenance activities. GE Plastics is engaged in an aggressive and comprehensive effort to identify and address Year 2000 issues. We are in the process of inventorying our equipment at the site, interviewing suppliers, putting into place corrective actions where necessary, and developing a contingency plan. We are on track to complete this process prior to critical roll-over dates and believe we have addressed the systems and equipment necessary for safe site operation. 0.6 FIVE YEAR ACCIDENT HISTORY The Ottawa, IL site has an outstanding record of accident prevention which demonstrates its commitment to public and worker safety. Even minor incidents are investigat ed to identify what went wrong and to learn how to prevent future occurrences. EPA requires that all incidents involving regulated chemicals that resulted in any off-site impact or significant on-site impacts are reported in this document. During the previous five-year period, one such incident occurred at the plantsite. On October 15, 1994, a 12,722-pound release of butadiene vapor occurred when a gasket failed on a vessel that manufactures latex. The butadiene was released through the 70-foot vent stack located south of the latex building. This venting reduced the amount of butadiene vapor that could have been released inside the latex building. The duration of the release was approximately one hour. There was no fire or environmental impact from this incident, and no one was injured. GE immediately reported the release to the Illinois EPA Emergency Response Center. As a precaution, GE requested the LaSalle County Sheriff to close Canal Road for a period of time while the problem could be corrected. GE's emergency response team conducted perimeter surveys for evidence of flammable vapors. No indication of flammable vapors was found during the survey at the site fenceline. 0.7 EMERGENCY RESPONSE PROGRAM The Ottawa, IL site maintains a written emergency response program designed to protect workers, the public, and the environment in the event of a major accidental release. All of our employees are trained in the proper response to an incident. We also invest in the equipment needed to respond to emergencies, both on-site and off-site. Our trained fire brigade, medical and chemical response teams work closely with area hospitals, industries, and other response organizations in the Marseilles - Ottawa, IL area. For example, during the last 2 years, the Ottawa Site Tactical Response Team (TRT) has received extensive training from the Illinois Fire Academy at the University of Illinois, at Mobil Oil, Joliet and the plant site involving fire fightin g methods, hazardous material response and advanced rope rescue. Emergency medical response is a part of the site TRT System. These personnel are trained by St. Mary's Hospital Emergency Room Staff to respond to potential medical emergency conditions at the Emergency Medical System - First Responder level. An ongoing training program has been in place for these personnel for the last 3 years. In order to ensure prompt medical attention for serious conditions, the Ottawa Site has coordinated with Life Flight medical helicopter support centers (St. Francis - Peoria and Loyola - Chicago) in the last 2 years. The Ottawa Site TRT is involved in a Mutual Aid Agreement with the Marseilles Area Fire Protection District. As a result of this agreement, GE Plastics TRT personnel were summoned to a major fire at a tire shredding facility east of Marseilles in March, 1998. Fire fighting operations for the TRT covered a total of 55 continuous hours and involved between 6 and 10 personnel with an average of 8 responders. Following this response, GE Plastics and the Marseilles Area Fire Protection District conducted joint training to further develop emergency response skills. Current plans call for: 7 Continuing the relationships developed in the Marseilles - Ottawa - Seneca Community Advisory Panel, meeting as often as is needed; and, 7 Working closely with the LaSalle County Local Emergency Planning Committee. Ongoing training exercises are important to the company's emergency response organization and help better prepare our partners in the community for emergency response necessary in the unlikely event of a major industrial incident. A tabletop drill was conducted in April 1999 to test the overall incident response capability. This drill included the Marseilles Fire Department, Ottawa Fire Department EMS Unit, and the community hospital of Ottawa. GE personnel are assisting the LaSalle County Local Emergency Planning Committee in the development of a countywide em ergency plan. As is consistent with the LaSalle County emergency plan, GE will work through the Marseilles Area Fire Department to communicate any appropriate actions to be taken by the public in the event of a chemical emergency. 0.8 PLANNED CHANGES TO IMPROVE SAFETY GE Plastics is committed to continuously improving the overall safety and environmental performance record at the Ottawa, IL facility. Some of the specific planned changes aimed at improving safety are: 7 Continuing development of best management practices under OSHA's Voluntary Protection Program (VPP); 7 Improved safety procedures and practices for control of hazardous energy during maintenance activities; 7 Continuing to develop and improve our environmental management systems to meet the world-class ISO 14000 standards in order to further protect and safeguard the environment; 7 Implementing behavioral based safety systems for employees to reduce the chance of human error leading to a workplace injury or an accidental release; and, 7 An ongoing employee exposure monitoring and reduction program for butadiene and acrylonitrile. |