GenCorp Performance Chemicals-Mogadore Latex Plant - Executive Summary |
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EXECUTIVE SUMMARY: This document was prepared as part of the Risk Management Program (RMP) of the Mogadore Latex Plant, Performance Chemicals Division of OMNOVA Solutions Inc.. The RMP conforms to the leqal requirements established by the U.S. Environmental Protection Agency (EPA). The purpose of the RMP plan is to: X Describe existing safety systems at the Mogadore Plant designed to protect employees, community, environment, and process. X Share information with the community about Mogadore Plant Operations including steps taken to minimize risk from regulated substances. X Comply with the applicable EPA regulations; 40 CFR Part 68 section 112(r) The following executive summary presents an overview of the Mogadore Latex Plant's accident prevention and emergency response programs. OMNOVA SOLUTIONS's COMMITMENT TO SAFETY: OMNOVA Solutions and its Mogadore operations are and always have been committed to safe operations as a number one priority since the Company began doing business at the site in 1950. The commitment begins with qualified people and is reflected in all levels of the operation. All employees at the Mogadore 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 safety from the conceptual stage through product development, manufacturing, and delivery to customers. Mogadore 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 industry averages. DESCRIPTION OF REGULATED PROCESS: The Mogadore Latex Plant produces Styrene/Butadiene and Styrene/Butadiene/Acrylonitrile latices for the papermaking and textile industries. Finished products are non-hazardous and are in the form of a visco us white liquid. 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. Mogadore operations have not had any accidents meeting this regulatory definition in the last 5 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 Mogadore facility is required to conduct Hazard Assessments of regulated process. 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 it's 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 Mogadore 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 Mogadore Plant. WORST CASE SCENARIOS: 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 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 Mogadore 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 vaults, and employees specially trained in handling and emergency response methods. Flammable Materials OMNOVA Solutions's Mogadore Plant has one regulated flammable substance covered by the regulation - 1,3 Butadiene. The plant's Worst Case Flammable Release Scenario involves the instantaneous loss of the entire content of its largest butadiene storage vessel, complete vaporization of the material, and a vapor cloud explosion of the entire content under the worst possible atmospheric conditions. The endpoint of a vapor cl oud explosion is defined as the distance at which the overpressure from the blast reaches 1 PSIG. OMNOVA Solutions does not consider this worst case likely; in fact , it may be physically impossible due to the array of active mitigation systems in place to prevent such an occurrence. These include deluge systems around the storage tank, flammable vapor sensors for early detection and diking to reduce the pool surface area and evaporation rate. Additionally, the atmospheric conditions required as input in the Model are unlikely if not impossible. For example, the temperature used must equal the highest area temperature in the last 3 years, usually occurring in the afternoon, and the wind must be very low with very stable air, usually occurring shortly after midnight. Toxic Materials OMNOVA Solutions's Mogadore plant has two regulated toxic materials on site, 29% Ammonium Hydroxide Solution, and Acrylonitrile. EPA regulations require one Worst Case Scenario to represent all reg ulated toxic materials. OMNOVA Solutions's Worst Case Toxic Scenario assumes the release of the entire of an Ammonium Hydroxide storage tank to the containment dike underneath , with the additional assumption that the material stays in the containment area without any mitigation measures to limit the amount that is evaporated to the atmosphere. . Again, Mogadore does not think this worst case is likely and may not 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. ALTERNATIVE RELEASE SCENARIOS: 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's Alternative Release Scenario for flammables is the instantaneous release of forty five pounds of 1,3 Butadiene as a result of an unloading hose failure. The di stance to endpoint, or 1 PSIG overpressure, from this scenario is 123 feet. This endpoint does extend beyond the nearest boundary of the facility; but there are no public receptors are within this radius. Toxic Alternatives The Alternative release scenario for 29% Ammonium Hydroxide Solution involves the loss of content from a 4 inch diameter transfer line approximately 400 feet long. The second Alternative Release Scenario involves a spill of Acrylonitrile to secondary containment for 10 minutes before draining to a tertiary containment vault. ACCIDENTAL RELEASE PREVENTION PROGRAM: OMNOVA Solutions began a formal Process Safety Management Program at its Mogadore facility in 1992 when OSHA promulgated 29 CFR 1910.119. Process Safety Management acting in concert with effective engineering design, Employee Safety Programs, Chemical Manufacturers Association Responsible CareR, EPA's RMP, and Emergency Response Programs make up the Mogadore Plant's Accidental Release Prevention Program. EMERGENCY RESPONSE PLAN: OMNOVA Solutions's overall safety efforts at Mogadore consist of measures to prevent the release of hazardous material, as well as programs to mitigate the effects if a release should occur. The Mogadore plant has a trained and equipped team of volunteer emergency responders capable of handling most foreseeable emergency situations. Importantly, coordination with local safety forces 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 OMNOVA Solutions's Mogadore facility. All covered process equipment design and modification is subject to formal Hazards Analysis Procedures. During a hazard analysis, recommendations are made for the improvement of the process. Since 1992 when the Process Safety Management regulation was promulgated, over 300 recommendations for process improvement have been implemented. Application of new design principals to existing equipment is also an important element of continuous process safety improvement. In addtion, formal accident and incident investigation procedures are in place so that causes of even the smallest failures are identified and corrected. |