OMNOVA Solutions Inc., Greensboro Plant - Executive Summary |
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EXECUTIVE SUMMARY: This document was prepared as part of the Risk Management Plan (RMP) of the Greensboro, NC Plant , Performance Chemicals Division of OMNOVA Solutions Inc.. The RMP conforms to the legal requirements established by the U.S. Environmental Protection Agency (EPA). This Risk Management Plan (RMP) is designed to: Inform the communities about Greensboro Plant Operations, including steps taken to reduce/ minimize risk of regulated substances. Describe existing Safety Systems at the Greensboro Plant to protect employees, community and the environment. Comply with the applicable EPA regulations: 40 CFR Part 68 section 112(r). The following executive summary presents an overview of the Greensboro Plant's accident prevention and emergency response programs. COMMITMENT TO SAFETY: Environmental, Health and Safety Policy OMNOVA Solutions Inc. and its Greensboro Operations are committed to Environmental, Health and Safety (EHS) excellence. This is a cooperative effort, re flected in the Greensboro Plant's EHS Policy, which states: X We will operate our facility in such way as to protect health and well being of our employees, community and the environment. X We will accomplish this by setting high standards and developing the people and methods to insure that those standards are maintained. X We will all own the responsibility for not only assuring our own safety but that of our co-workers as well. X We can, through proper training, willing and active participation by everyone and focusing on the job at hand, accomplish our primary goal of protecting employees, community and the environment. DESCRIPTION OF REGULATED PROCESS: OMNOVA Solutions' Greensboro Plant produces chemicals and emulsions used for processing and finishing textile fabrics; in coatings for paper, packaging, industrial application, graphic arts. The facility has one regulated substance covered by the regulation - Formaldehyde - used in the production of permanent press finishing resins for the Textiles industry. The finished product resins are in the form of non-hazardous clear liquids. FIVE (5) YEAR ACCIDENT HISTORY: The EPA regulations require regulated facilities to provide information about all accidents in the last 5 years involving an RMP regulated substance if the accident resulted in (1) death, injury according to the RMP definition, or significant property damage on site, or, (2) known deaths, injuries, property or environmental damage off site. Greensboro Operations have not had any accidents meeting the regulatory definition in the last five years. HAZARD ASSESSMENTS: As part of the EPA regulations, Process Safety Management requirements of the Occupational Safety and Health Administration (OSHA), and the Chemical Manufacturers Association (CMA) Responsible CareR Commitment, the Greensboro facility is required to conduct Hazard Assessments of regulated processes. EPA regulations specifically require 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 regulations 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 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 its release scenarios. While these models may be more accurate, they can still result in highly improbable and in some cases physically impossible risk scenarios. For example, neither lookup tables nor models allow consideration of existing active safety devices such as sprinkler systems, which can reduce the severity of an accidental release. The models also increase the number of specific data points examined and, thus, present the most accurate information possible 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 Greensboro facility. Alternative Release Scenarios are by definition more likely to occur than Worst Case Scenarios but are still very improbable due to engineering and administrative controls at the Greensboro Plant. WORST CASE SCENARIO: 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 regulated 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 reg ulated 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 Greensboro facility to effectively prevent these situations. These measures, most of which were not taken into consideration under the EPA regulations include leak detection systems, continuous monitoring and automated controls, automatic shutdowns, deluge water systems, secondary containment dikes, and employees specially trained in handling and emergency response methods. Flammable Materials The Greensboro Plant does not use any of the 63 listed flammable substances above the regulated threshold. Toxic Materials The Greensboro Plant only uses one of the 77 regulated toxic substances on site above the regulatory threshold, 37= % Formaldehyde Solution. OMNOVA Solutions' Worst-Case Scenario for a regulated toxic substance is the release of the entire contents of the Formaldehyde storage tank. This scenario assumes that the spill flows to the plant's equalization basin and that the entire contents of the storage tank would spill and vaporize. It also assumes, unrealistically, that facility employees would do nothing to mitigate the release. OMNOVA Solutions does not think that this worst case is likely and, in fact, it may not even be possible due to the conservative assumptions required by the regulation. An array of mitigation techniques are in place to reduce the severity of any potential release, including trained operation personnel, control systems, Emergency response Program, and system hazard review. ALTERNATIVE RELEASE SCENARIO MODEL: Applicable EPA regulations also require facilities to submit one alternative release scenario to represent all flammables and one to represent each toxic material. Flammable Alternative: OMNOVA Solutions' Greensboro Plant uses none of the 63 listed flamm able substances above the regulated threshold. Toxic Alternatives The Greensboro Plant's alternative release scenario model also involves formaldehyde (37= % solution). It assumes a pipeline gasket fails during transfer of material spraying solution during a period of one hour. While this is a more realistic presentation of what could happen at the Greensboro Plant, this type of incident still remains highly unlikely given the fact that trained personnel are ready to respond. ACCIDENTAL RELEASE PREVENTION PROGRAM: OMNOVA Solutions has initiated a formal Process Safety Management (PSM) program at the Greensboro facility. PSM in concert with effective engineering design, Employee Safety Programs, Chemical Manufacturers Association Responsible Careb, and Emergency Response Programs make up the Greensboro Plant's Accident Release Prevention Program. EMERGENCY RESPONSE PROGRAM: OMNOVA Solutions' overall safety efforts at Greensboro consist of measures to prevent the release of haza rdous material, as well as programs to mitigate the effects if a release should occur. The Greensboro Plant has a trained and equipped emergency operations level team capable of handling most 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. PLANNED CHANGES TO IMPROVE SAFETY: Intrinsic safety is a key element in the design of all process equipment at the facility. All covered process equipment design and modification is subject to formal hazard analysis procedures. During hazard analysis, 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 improve emergency response capabilities. Process equipment upgrades to the resin manufacturi ng system are also planned as part of the plant's commitment to continuous improvement. |