OMNOVA Solutions Inc. Chester Plant - Executive Summary

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This document was prepared as part of the Risk Management Plan (RMP) for the OMNOVA Solutions Inc. Chester facility, Performance Chemicals Division. The RMP conforms to the legal requirements established by the U.S. Environmental Protection Agency (EPA). The purpose of this RMP is to: 
7 Describe existing safety systems at the Chester facility that are designed to protect employees, community, environment, and assets; 
7 Share information with the community about plant operations including steps taken to minimize risk from regulated substances and response to emergency conditions 
7 Comply with the applicable EPA regulations:  40 CFR Part 68. 
The following executive summary presents an overview of the Chester facility's accident prevention and emergency response programs. 
OMNOVA Solutions and its Chester operations are and always have been committed to safe operations as a high priority. The commitment begins with qualified p 
eople and is reflected in all levels of the operation.  All employees at the plant are given the training, tools, and empowerment to perform their part of the operation in a safe manner.    Strict operational controls are in place to ensure a safe facility from the conceptual design stage through the final delivery of products to customers.  Chester has a staff of Safety and Environmental Professionals, Engineers, and Security personnel to assure implementation of an ongoing commitment to the highest standards of safe process management.  This experience and professional competency has resulted in many years of safe operations consistently exceeding the industry average. 
OMNOVA Solutions, Chester Plant has three regulated processes.  One process uses 50% Formaldehyde Solution (49% Water) in the production of permanent press finishing resins for the Textiles industry. These resins are non-hazardous clear liquids.  Ethylenediamine is used in the prod 
uction of polyamide resins for the Graphics industry. These polyamide resins are non-hazardous solids.  Vinyl Acetate is used in the production of latex polymers for the Paper, Textiles, and Non-wovens industries.  These latex polymers are non-hazardous white liquids (water based). 
The EPA regulations require regulated facilities to provide information for all accidental releases from regulated processes that resulted in (1) deaths, injuries according to the RMP definition, or significant property damage on site, or, (2) known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 
No accidents meeting this regulatory definition have occurred at the Chester facility within the last five years. 
As part of the EPA regulations, Process Safety Management requirements of the Occupational Safety and Health Administration (OSHA), and the Chemical Manufacturers Association Responsible Careb commitme 
nt, OMNOVA Solutions is required to conduct Hazard Assessments of its regulated processes. The Risk Management regulation also specifically requires offsite consequence analyses in the form of Worst-Case Scenarios and Alternative Release Scenarios for certain regulated substances. 
OMNOVA Solutions is concerned that these Worst-Case Scenarios, required to be disclosed under the regulation, may overstate the risk of a worst case release.  For example, the EPA published lookup tables do not take any local physical conditions into account.  An alternative to the lookup tables (allowed by the regulation) is to calculate release scenarios based upon recognized risk analysis techniques, or "models."  Limited consideration of local conditions is used in the models within strict EPA guidelines.  Accordingly, OMNOVA Solutions uses the EPA recognized models in preparing it's release scenarios. While these models may be more accurate, they can still result in highly improbable and in some cases p 
hysically impossible risk scenarios.  For example, neither lookup tables nor models allow for consideration of existing active safety devices such as in-place sprinkler systems to reduce the potential severity of an accidental release.     The use of models increases the number of specific data points examined and, thus, presents more accurate information using all required inputs. 
OMNOVA Solutions has also prepared Alternative Release Scenarios which it believes are more accurate predictions of potential accidental releases from the Chester facility.  Alternative Release Scenarios are by definition more likely to occur than the Worst-Case Scenarios but are still very improbable due to engineering and administrative controls in the facility's prevention program.   
EPA regulations require facilities to develop one Worst-Case scenario to represent all toxic substances and one Worst-Case scenario to represent all flammable substances from a list of regul 
ated materials.  Additional Worst-Case Scenarios are required if different public receptors (off site residences, businesses or community buildings within a possible impact radius) could be affected by the release of another regulated material.  OMNOVA Solutions is not subject to this additional requirement. 
When examining the following Worst-Case and Alternative Release Scenarios, it is important to keep in mind that OMNOVA Solutions has numerous preventative measures in place at its Chester facility to effectively prevent these situations.  These measures, most of which were not taken into consideration under EPA regulations, include leak detection systems, continuous monitoring, automated controls, emergency shutdowns, secondary containment and employees specially trained in handling these materials and in emergency responses methods. 
Flammable Materials 
The Chester facility uses none of the 63 listed flammable substances above the regulated threshold.   
Toxic Materials 
The Chest 
er facility only uses 3 of the 77 regulated toxic substances on site above the regulatory threshold.  These are 50% Formaldehyde Solution, Ethylenediamine, and Vinyl Acetate. 
The Worst-Case Scenario for a regulated toxic substance is the release of the entire contents of a Vinyl Acetate railcar.  This scenario assumes that there is no containment of the material and that the entire contents of the railcar would spill and vaporize.  It also assumes, unrealistically, that facility employees would do nothing to mitigate the release to limit the amount that is evaporated to the atmosphere.  OMNOVA Solutions does not think that this worst-case is likely and may not be possible due to the conservative assumptions required by the regulation. 
Applicable EPA regulations also require facilities to submit one alternative release scenario to represent all flammable substances and one to represent each toxic substance.  
Flammable Alternative 
The Chester facility d 
oes not use any of the listed flammable substances above the regulated threshold.   
Toxic Alternatives 
The facility is required to submit three alternative scenarios, one for each of the three toxic substances listed above. 
The Alternative Release Scenario for Vinyl Acetate involves failure of a pressurized pipeline, which would result in spraying material outside the storage containment area.  
The Alternative Release Scenario for Formaldehyde involves failure of a tank truck unloading hose, resulting in a release of 50% Formaldehyde Solution from the hose. 
The Alternative Release Scenario for Ethylenediamine involves failure of a transfer line or gasket, which would result in the material being released outside the storage containment area. 
OMNOVA Solutions' Chester facility began a formal Process Safety Management Program in 1992 when OSHA promulgated '29 CFR 1910.119.  Process Safety Management in concert with effective engineering desig 
n, Employee Safety Programs, Chemical Manufacturers Association Responsible Careb, and Emergency Response Programs make up the Chester Plant's Accident Release Prevention Program. 
OMNOVA Solutions' overall safety efforts consist of measures to prevent the release of hazardous materials, as well as programs to mitigate the effects of a release should it occur.  OMNOVA Solutions has a trained and equipped emergency response team capable of handling foreseeable emergency situations.  Coordination with local emergency response agencies is a key element of the emergency response planning process.  Specific plans are in place to respond to chemical emergencies within the facility. 
Intrinsic safety is a key element in the design of all process equipment and systems at OMNOVA Solutions' Chester facility.  All covered process equipment design and modification is subject to formal hazard analysis procedures.  During a hazard ana 
lysis, key recommendations are made for improvement to the process.  Application of new design principles to existing equipment is a key element of continuous process safety improvement. 
Continued training and planned drills will sustain and improve emergency response capabilities.    
In 1999, an earthen dam will be installed below the rail spur where Vinyl Acetate rail cars are unloaded to provide for containment of the entire contents of a rail car to significantly reduce the potential impact of the disclosed Worst-Case Scenario.
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