Specialty Polymers, Inc. - Executive Summary |
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RISK MANAGEMENT PLAN SPECIALTY POLYMERS, INC. CHESTER, SC Executive Summary (40 CFR 68.155) Background Data In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Specialty Polymers, Inc. (SPI) submits this Risk Management Plan (RMP) for operations at their new facility in Chester, South Carolina. SPI is a chemical manufacturing facility. Operations include the manufacture of polymer resins and emulsions. SPI has been producing quality products at their main facility in Oregon for over 27 years and provides over 50 jobs to the local community. The new plant in South Carolina was built with "safety" as a primary goal, using state-of-the-art equipment. Approximately 10 employees are anticipated to operate the Chester facility. Accidental Release Prevention and Emergency Response Policy SPI is committed to protecting the health of its employees, the surrounding community, and the environm ent; therefore it is SPI policy to maintain compliance with 40 CFR 68 as well as Occupational Safety and Health Organization (OSHA) Hazardous Operations and Emergency Response regulations (29 CFR 1910.120), OSHA's Emergency Plans and Fire Protection Plans (29 CFR 1910.38), and OSHA's Hazard Communication regulations (29 CFR 1910.1200). Stationary Sources and Regulated Substances At SPI, vinyl acetate monomer (CAS 108-05-4) is reacted to produce a product for industrial distribution. SPI's system consisting of two (2) bulk storage tanks, a reactor vessel, and associated piping can contain a quantity of vinyl acetate in excess of the 10,000 pound threshold given in Appendix A of 40 CFR 68. Worst Case Release Scenario As required by 40 CFR 68 Subpart B, SPI has evaluated a worst-case release scenario for vinyl acetate using the parameters specified by the EPA. SPI's worst-case release scenario is the rupture of the largest single tank (bulk storage tank) into a diked containment are a resulting in a toxic liquid pool. In developing the release parameters of this worst-case scenario, SPI considered passive mitigation provided by the newly built dike enclosure, designed specifically for toxic containment and spill prevention. Volatilization rate of the toxic liquid was determined using the EPA guidance document. Using the EPA's RMP*Comp program, it was determined that the distance to the toxic endpoint in this worst-case scenario has the potential to result in an offsite release. The worst-case release scenario was developed following EPA regulations and is not considered to be a likely release scenario. Alternative Release Scenarios SPI evaluated several options to be considered as alternative release scenarios. After careful consideration, SPI decided that the scenario more likely to occur than the worst-case scenario, which could result in an offsite consequence, is the sheering of a vinyl acetate process pipe. It is assumed that a vinyl acetate release from a sheered transfer line would result in a small liquid pool and volatilize. In developing the release parameters of the Alternative Release Scenario, SPI considered average response time to shut the system down and pressure loss sensors disabling the transfer pump as an active mitigation. Using EPA's RMP*Comp program and EPA's RMP Offsite Consequence Analysis Guidance Document, the distance to the toxic endpoint in the alternative release scenario has the potential to result in offsite consequences. Accidental Release Prevention Program To prevent and mitigate accidental releases of vinyl acetate monomer, SPI has implemented several precautionary measures. SPI has developed and will implement an Emergency Action Plan and a Hazardous Materials Contingency Plan. SPI has also complied with EPA's 112r General Duty clause. As such, the vinyl acetate system has been evaluated for release potential. Some of the controls installed to prevent catastrophic releases of vinyl acetate are process controls (vents, relief valves, check valves, rupture disks and manual shutoffs) and automated controls (process area detection systems, interlocks and automatic shutoffs via remote switch or computer modem). SPI has developed standard operating procedures (SOPs) with incorporated safety measures for all employees and contractors that have contact with the vinyl acetate system. SPI encourages employee participation in the development of the control measures used at the plant. Employees have the opportunity to voice opinions, concerns, questions, or ideas during the monthly training sessions or during the quarterly safety meetings. For topics that require more immediate attention, SPI employees may approach their supervisor directly or place suggestions in the suggestion box. SPI understands that maintaining the system in good working order is essential to preventing accidental releases. As such, SPI will conduct preventive maintenance on the process equipment on a m onthly basis. The preventive maintenance program is scheduled, documented and managed to ensure that regular maintenance occurs on the system. To confirm that control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits will be performed on the vinyl acetate system. SPI will conduct compliance audits every three years. Since the vinyl acetate system was recently installed this year, the first compliance audit will be conducted in the year 2002. Five-Year Accident History The Chester facility was newly built this year thus has not experienced an accidental offsite release of vinyl acetate monomer. Emergency Response Program SPI has documented emergency response procedures in order to facilitate response efforts in the event of an offsite release of vinyl acetate. Included in the emergency response program are measures to be taken internally by SPI employees and procedures to inform local emergency response agencies. To assure that the local municipal response agencies are familiar with SPI's emergency response procedures, copies of the emergency response document will be submitted for review and approval by the local agencies. Chester County Local Emergency Planning Committee (LEPC) will review SPI's emergency response procedures. In the event of a vinyl acetate release resulting in offsite consequences, the general public will be notified by the Chester County LEPC. Planned Changes to Improve Safety SPI has implemented a continuous training program to improve safety awareness. |