Geon Company - Henry Plant - Executive Summary |
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Geon Company Henry Plant Environmental Policy The Geon Company Henry Plant, a producer of Vinyl Chloride Resins, is fully committed to conducting operations in a manner protective of the environment benefiting both our employees and community. We will accomplish this by: 7 Complying with all applicable federal, state and local regulations and permits. 7 Proactively finding ways to continually improve in our environmental performance and prevent pollution through teamwork and innovation as supported by the Geon Corporate Policy. 7 Utilizing The Chemical Manufacturers Association's "Responsible Care Program" for clear guidance towards conducting our operations in an environmentally safe manner benefiting our employees and community. 7 Communicating this policy to all employees and other interested parties, and to manage its effective implementation through employee participation and the use of the Environmental Management System. Joel Lindahl April 1999 Plant Manager Geon Company Henry Plant Safety and Health Policy We are committed individually, and as a team, to ensure that everyone who comes into the plant returns home uninjured and healthy. We continuously strive to improve our process, procedures, and work systems in meeting this objective. THE GEON COMPANY ENVIRONMENTAL POLICY It is the policy of The Geon Company to conduct our operations in a manner fully protective of employees, customers, public health and the environment. Implementation of this policy shall be through programs, which are proactive in nature and go beyond compliance with applicable laws and regulations. Geon's commitment to the principles of Responsible Care provides clear guidance for action. We will conduct ongoing evaluation of our operations and products to identify practical opportunities for continuing reduction of releases and wastes. We are committed to a continued reduction of emissions and permit exceedances, as well as, minimizing the generation of solid and hazardous wastes. Excellence in program leadership and stewardship is a key management responsibility. Insuring that all operations in the company are carried out in accordance with this Policy is the responsibility of each employee. SAFETY AND HEALTH POLICY The policy of our Company is to safeguard the health and well-being of each employee and our neighbors. Implementation of this policy shall be through the elimination of accidents and by establishing through our activities, safety and health management among the highest corporate priorities. This pol icy applies to all employees and contractors to The Geon Company. Ensuring the safety of all personnel is everyone's concern and requires a constant sense of awareness and attention to detail. The development of safety awareness can only come through each person's acceptance of his responsibility for safety in conjunction with adequate job orientation, training, recognition and communication of the hazards associated with each work situation. Everyone must believe that all accidents are either preventable or avoidable. Effective management of our process safety is critical in maintaining the integrity of our operations. All necessary equipment, tools, technologies, procedures, and training will be provided to assist everyone in operating our processes and performing their jobs safely. At Geon every job and operation must be managed safely. Safety performance will be a key element of each employee and contractor's performance evaluation. Excellence in safety performance is a con dition of employment at Geon. The prevention of accidents while off the job is equally important. The same principles at work are also effective in preventing accidents in the home, on the highway and in all other activities. Working and living safely must be our way of life. W. F. Patient Chairman of the Board President and CEO SUMMARY OF REGULATED SUBSTANCES The Geon Company located in Henry, Illinois has one regulated flammable substance identified for the Accidental Release Prevention Program (40 CFR Part 68.130) above the Threshold Quantity (TQ) of 10,000 pounds: Vinyl Chloride Monomer (VCM) (CAS No. 75-01-4). No toxic chemicals listed in the Accidental Release Prevention Program exceed the TQ. RELEASE SCENARIOS The worst-case release scenario(s) and the alternative release scenario(s), including administrati ve controls and mitigation measures to limit the distances for each reported scenario are outlined herein: WORST-CASE RELEASE SCENARIO Failure of one spherical storage tank would release 2,000,000 pounds of Vinyl chloride. It is assumed that the entire contents of the sphere are released as a vapor, which finds an ignition source. Ten percent of the release quantity is assumed to participate in the resulting explosion. Using the equations for calculating over pressure from the RMP Offsite Consequence Analysis Guidance Document (OCAG). 7 The distance to the endpoint of 1 psi overpressure equals 0.76 miles. Using Fire Radiation Table 22, page 70 of OCAG. 7 The distance for radiant heat dose of 5 kW/square meter is 0.85 miles. ALTERNATIVE RELEASE SCENARIO An overpressurization of a tank rupture disk or relief valve results in a release of 12,000 pounds of vinyl chloride. The entire contents of the tank are released over 2 minutes. Unconfined vapor travels to the lower flamma bility limit (LFL). The distance to the endpoint for the LFL for the alternative scenario is less than 317 feet or 0.06 miles. Using Exhibit C-2, page 100 of OCAG. 7 LFL of VCM is 92 mg/l Using Reference Table 21, page 66 of OCAG. 7 Distance to LFL for 6,000 pound/minute release rate is <0.06 miles (<317 feet) PREVENTION PROGRAM The Geon Company has in place a prevention program encompassing elements consistent with the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM) for Highly Hazardous Chemicals (29 CFR 1910.119). VCM, the same substance is regulated under the USEPA Clean Air Act Section 112(r)(7) Accidental Release Prevention Requirements: Risk Management Programs (RMP)(40 CFR Part 68). NOTE: Geon Henry facility has applied for, but not yet issued a Title V operating permit. The Geon facility, which is covered under the PSM and RMP standards, has implemented the following: 1. An Employee Participation policy has been institut ed to regularly consult with employees regarding the development and implementation of PSM/RMP elements and hazard assessments. 2. A comprehensive Process Safety Information program, which insures complete and accurate written information concerning process chemicals, process technology and process equipment. This information is included in the employee training programs. 3. Process Hazard Analysis (PHA) is conducted to identify and analyze the potential hazards associated with the processing or handling of highly hazardous chemicals. 4. The preparation of Operating Procedures that describe tasks to be performed, operating conditions to be maintained, data to be recorded, and safety precautions to be taken. 5. The Geon Company has established Employee Training programs to insure that all employees, including maintenance and contractor employees involved with chemicals, fully understand the potential hazards of each chemical. The Geon Company has established an "Operator Certi fication" program to train, test and certify company employees. 6. Contractors are thoroughly evaluated to insure that they have the appropriate job skills, knowledge and certifications to perform the job safely. 7. For new processes, a Pre-Startup Safety Review is conducted to insure a safe transition into the normal operating mode. 8. A Mechanical Integrity program is in place to assure the integrity of process equipment. Elements include the following: 7 identification and categorization of equipment and instrumentation 7 inspections and test 7 establishment of prescribed inspection frequencies 7 development and application of pertinent maintenance procedures 7 training of maintenance personnel 7 documentation of test and inspection results 7 documentation of manufacturer's maintenance recommendations 9. A "Hot Work" Permit system is in place to manage welding, cutting or brazing of equipment in process areas. 10. To properly manage changes involving processes, chemical, technology, equipment or facilities a Management of Change system has been implemented. 11. In the event of any chemical release or "near miss", a team of experienced individuals familiar with the process conducts an Incident Investigation Any recommended changes are documented within the Management of Change system. 12. An Emergency Response program is in place for the entire facility and the surrounding community in the event of a chemical release. 13. Compliance Audits are performed to review all relevant documentation, verify process safety information, inspect the physical facilities and conduct interviews with representative plant personnel. FIVE YEAR ACCIDENT HISTORY During the past five years The Geon Company has had no chemical releases which created an emergency situation outside the plant boundaries nor resulted in any deaths, injuries, or significant property damage onsite or known offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage. EMERGENCY RESPONSE PROGRAM The Geon Company has in place the following "Emergency Procedures" for handling accidental releases of chemicals: 7 Fire Emergency Procedure 7 Gas Alarm Procedure 7 Emergency Evacuation Procedure 7 Notification Procedure 7 Spill Prevention Control and Countermeasure Plan A notification system is in place to initiate response to any emergency. Key personnel are notified via plant alarms, pagers and telephone. Once notification has occurred, key personnel follow a series of emergency plans. For example, in the event of a fire, the Firebrigade Team will respond and an onsite Chain of Command communication system is implemented. The Firebrigade Team is trained to deal with chemical releases and emergencies. All members are trained in First Aid/CPR. Coordinated drills with the Henry Volunteer Fire Department, neighboring industry, Marshall County ESDA, and the Local Emergency Planning Committee (LEPC) are conducted to insure good communication and operational effectiveness. These exercises are conducted annually at a minimum. The Geon Company participates in the Chemical Manufacturers Association's (CMA) Community Awareness Emergency Response (CAER) Code of Management practices. FACILITY IMPROVEMENTS The Geon Company plans to continue to evaluate the regulated process as required under the PSM/RMP Standards to insure safe operations. Additionally, the company will continue to work with the local fire department, ESDA and LEPC to coordinate training drills and information. The Geon Company annually performs a complete facility review to verify an effective Environmental, Safety and Health progr am. |