Specialty Polymers, Incorporated, Woodburn - Executive Summary |
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EXECUTIVE SUMMARY 1. Introduction In a series of rules promulgated between 1994 and 1998, the U.S. Environmental Protection Agency established the Risk Management Program (RMP) under Clean Air Act Section 112(r). The RMP contains a list of toxic and flammable chemicals. Facilities that manage more than a threshold amount of a listed chemical may be subject to the RMP. Covered facilities must assess the risks associated with their management of the listed chemicals and produce a plan to prevent releases and accidents. In order to assist in emergency planning, covered facilities must evaluate "worst case" and "alternative case" scenarios that would result from the release of a listed chemical. Finally, the covered facility must make their risk management program available to the public. This document is part of the Specialty Polymers Incorporated Woodburn Plant's RMP communication effort. This document comprises the RMP plan for the Specialty Polymers Incorporated Woodburn Plant. The plan contains a description of all the procedures and provisions to reduce the likelihood and severity of an RMP regulated substance release or accident. The RMP plan is based upon a complete assessment of the processes, operations, and procedures of the plant and an analysis of potential releases of RMP regulated substances that may occur at the plant and their impacts on the offsite populations. 2. Accidental Release Prevention and Emergency Response Policies SPI has a long-standing commitment to provide a safe workplace and to prevent accidental releases. This commitment is set forth in SPI health and safety policies: * We will ensure our operations and products are free from significant risks to the health and safety of our employees, customers, carriers, distributors, the general public, and to the environment. * We will meet or exceed all applicable laws and regulations, participate in voluntary initiatives, and strive for continual improvement in our Environmental, Health, a nd Safety performance. * We will provide our employees with a safe workplace end support their efforts to work safely. * We will strive to eliminate or reduce emissions, discharges, and wastes from every stage of our operations. '* We will communicate, listen and be responsive to our employees, customers, neighbors, and governments, and we will share information concerning potential hazards resulting from our operations or our products. SPI is committed to proactive analysis for hazard identification and mitigation. We have formal programs to verify our facility is being operated in accordance with accepted industry practices, company standards and legal requirements. The types of risk management programs required by the RMP have long been in place at SPI Woodburn. Safe operation is a plant and company priority, and is reflected in policies as well as everyday activities. We welcome the EPA/RMP Initiative and see it as an opportunity to expand dialog with our community and to help improve our safety performance. 3. General Description of the Stationary Source The SPI Woodburn Plant is a specialty chemical manufacturing facility that produces a variety of non-hazardous water-based polymeric emulsions. This activity Is described by SIC code 2821 and NAICS code 325211. Approximately fifty different products are manufactured at the plant using different mixtures of reactants. These products are used by our customers to manufacture water-based paints, adhesives, caulks, and other household and industrial products. The SPI facility is located in the city of Woodburn, Oregon at 2475 Progress Way, 0.26 miles north west of the intersection with Hood Avenue. The plant is constructed on a parcel of approximately 5 acres. The polymeric emulsions are produced in three parallel process units in Building 1. All of the products are manufactured in batch operations. The major raw materials used are monomers, and are received by railcar and tank truck. 4. RMP Regulated Sub stances One RMP regulated substance in, use at the SPI Woodburn Plant, Vinyl acetate monomer. The Vinyl acetate process vessels used in the manufacture of emulsions are mechanically and electronically monitored and alarmed to notify process personnel of potentially unusual pressures and temperatures. Process feed rates are controlled automatically to manage the reaction, and standard operating procedures are in place to safely manage the chemicals, the reactions, and any unusual events. Operators are rigorously trained, updated and tested on the standard operating procedures Vinyl Acetate is almost always received by rail car and pumped, via the top loading system, to the storage tank through installed steel lines. The rail siding is protected by a spill collection system that provides the means to pump spilled material into the storage tanks. When Vinyl acetate is transferred to Building 1, the quantity required is pumped to a load cell controlled load back tank. It is then pumpe d into a mixing vessel, which contains the water required for the emulsion and is mixed with additives and reacted. This process absolutely prevents over charging, and the water in the reactor is sufficient to prevent a runaway reaction. When the reaction is essentially complete the Vinyl acetate is converted to a polymer and is no longer hazardous. 5. Offsite Consequence Analysis Results Releases of Vinyl acetate from the SPI Woodburn Plant has potential off-site consequences. The RMP rule provides detailed requirements that define a worst case scenario as that release which is estimated to travel the greatest distance in any direction under worst case weather conditions, with only passive mitigation systems in effect. EPA notes that the worst case scenario is designed principally to support a dialogue between the source and the community on release prevention, and not to serve as the sole or primary basis for emergency planning. Based on previous Plant history, in addition to the several layers of protection in place, this worst case scenario is highly unlikely to actually occur. The SPI Woodburn Plant worst care scenario assumes a storage tank rupture due to a major earthquake and the instantaneous release of 280,000 pounds (36,000 gallons) of Vinyl acetate onto a containment dike (44,392 gallons capacity) with a surface area of 2853 Sq.Ft. This tank is near the center of the facility and is protected from vehicle traffic by reinforced concrete walls. All lines in the chemical management system are contained in protected, covered concrete trenches. The storage facility has been evaluated and found to be satisfactorily engineered for this risk. This scenario is extremely unlikely to actually occur in as much as Woodburn is not considered to be in a high earthquake risk zone. Historic information published by the Oregon Department of Geology and Mineral Industries indicates that there is a 5% probability in 50 y ears of an event causing more than slight damage to the storage tank. The RMP rule also defines alternative release scenarios. Unlike worst case scenarios, active mitigation and safeguards, such as alarms, automatic shutdowns, and operator interventions can limit the alternative release scenario. According to EPA, the alternative release scenario is a more useful communication tool for the public and first responders for emergency response preparedness and planning. The alternative case scenarios for the Plant were chosen after review of the Plant spill history, process hazard analyses, and discussions regarding potential scenarios with knowledgeable and experienced operating department personnel. The identified scenarios are more credible than the worst case scenario, but remain unlikely due to the design of the equipment and training of our employees. The alternative case scenario of a break in the two-inch transfer line was chosen for Vinyl acetate. The scenario assumes that pro per response would limit the quantity released to 1600 pounds in a five-minute response time. Because of automatic controls and alarms, release should be limited to not more than 320 pounds. It is assumed that the material would be released during slightly unstable weather conditions and moderate wind speed. Again, the spill-control trenching system limits the exposed surface area of the pool that would result and reduces the release rate to the atmosphere. Computer modeling indicates that the effects from such a release would also extend just beyond the Plant boundaries. 6. SPI Woodburn Plant Accidental Release Prevention Program and Chemical-specific Prevention Steps The SPI Woodburn Plant is fully committed to maintaining a safe workplace. We prevent accidents by taking measures to create and maintain safe conditions in all aspects of our operations including design, operations, and handling. Examples of our safety protection measures Include: * Redundant safety systems and instr umentation * Secondary containment for storage tanks * Alarm systems and automatic shutdown devices for critical control parameters * Pressure relief devices to prevent overpressurization * Fire protection and vapor suppression systems * Written procedures and training programs * Highly trained and experienced operators * Operator surveillance of unloading operations * Permit system to control work in hazardous areas * Preventative maintenance program for equipment * Work preplanning * Controlled entry to Plant site * Environment, Health, and Safety (EHS) review for managing change in new and existing processes Plant prevention programs are designed in accordance with the OSHA PSM and EPA RMP standards. 7. Summary of the Five-year Accident History There been no accidental releases of Vinyl acetate at the SPI Woodburn Plant that resulted in deaths, injuries or significant property damage on site or known offsite death, injuries, evacuations, sheltering in place, property damage or e nvironmental damage since the facility was constructed in 1973. 8. Summary of the Emergency Response Program SPI holds only one regulated toxic substances over threshold quantities (Vinyl acetate). The facility is included in the community emergency response plan developed under the Emergency Planning and Community Right-to-Know Act (EPCRA). Under ?68.90(b), SPI employees only act to stop and contain the spill, evacuate the facility as required, and notify the offsite responders. A senior management employee is is designated as Facility Emergency Coordinator, on call, and will respond. He is authorized to expend necessary funds and is qualified to furnish facility information and technical support to emergency responders. As a part of it's over riding commitment to work place and community safety and environmentally sound business practices, SPI maintains, as a part of it's Health and Safety Plan, an emergency plan to mitigate the impact of releases, accidents, fires, explosions, na tural disasters, and health emergencies not associated with this regulated chemical. This practice will further mitigate the probability of a Vinyl acetate release through involvement in an unrelated incident. 9. Planned Changes to Improve Safety It is our belief that effective environmental, health, and safety systems must be continually improved. We Constantly strive to recognize areas for improvement and implement the changes necessary to achieve our goals. We have developed end put Into place sufficient layers of protection to prevent escalation from a single failure to a catastrophic event, and are continually reducing the potential for the worst-case scenario or any kind of accident. SPI has installed a new computer system for production and business management. This will allow automated monitoring and reporting of facility and production equipment maintenance, eliminating the manual system now used. SPI plans to reduce the surface area of the Vinyl acetate storage tank dike to less than 2000 Sq.Ft. and extend the dike to three feet high to maintain the capacity. This will reduce the end point of a release to 0.4 miles. There are no schools or housing units in this radius. Potential human exposure will be reduced from 590 to 130. |