PolyOne Corporation - Executive Summary
THE POLYONE CORPORATION, PEDRICKTOWN, NEW JERSEY FACILITY DESCRIPTION |
The PolyOne Corporation is a leading North America based polymer technology and service company with operations in polyvinyl chloride compounds and other value-added products and services, as well as polyvinyl chloride resins. Headquartered in Cleveland, Ohio, the PolyOne Corporation and its subsidiaries employ more than 10,000 people and have 80 manufacturing plants worldwide. The Pedricktown facility manufactures speciality dispersion resins. Dispersion resins are used in a wide array of products including resilient vinyl flooring, vinyl gloves, toys, weather stripping, spray coating, can coatings, carpet backing, adhesives and adhesive bandage strips.
During the last two years, PolyOne Corporation has proactively been discussing the most recent Risk Management Program regulatory requirements with community and county officials. This activity included educational sessions and tours with emergency respons
e personnel, discussion of regulated materials and the prevention programs in place to prevent releases, emergency response capabilities and methods and considerations used to calculate worse-case and alternative release scenarios. This proactive activity included sharing all of the information with the general community in May 1999.
ACCIDENTIAL RELEASE PREVENTION & EMERGENCY RESPONSE POLICY
The PolyOne Corporation has a strong commitment to accidental release prevention and emergency response as stated in the Plant Manager's Safety and Health Message, Company Environmental Policy and Company Safety and Health Policy. PolyOne Corporation has fulfilled this commitment through a long history of outstanding safety performance, including receipt of the New Jersey Governor's Award and numerous industry and company awards for safety and environmental excellence. PolyOne Corporation has also provided long term leadership in emergency response preparedness for both the Pedricktown com
munity and Salem County.
PLANT MANAGER'S SAFETY& HEALTH MESSAGE
The Safety and Health of all employees and visitors to the Pedricktown Plant is our first and foremost priority. Any job that cannot be done safely will not be done. All employees and visitors are encouraged to use all of the supplied safety procedures, training, and tools to prevent injuries both on and off the job. All employees and visitors have the "License to be safe" and are authorized to delay the start of any task or job until all of their safety concerns have been satisfied. With each of us personally responsible for our own safety and well-being, our plant will continue to be successful and viable in the future.
It is the policy of the PolyOne Corporation 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. PolyOne Corporation'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 waste.
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 & 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 policy applies
to all employees and contractors to the PolyOne Corporation.
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 the PolyOne Corporation, every job and operation must be managed safely.
Safety performance will be a key element of each employee's and contractor's performance evaluation. Excellence in safety per
formance is a condition of employment at PolyOne Corporation.
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.
PolyOne Corporation is regulated under the OSHA Process Safety Management Standard and the New Jersey Department of Environmental Protection (NJDEP) Toxic Catastrophe Prevention Act (TCPA), which regulate the management of process safety. The OSHA Process Safety Management Standard regulation is designed to protect workers from catastrophic process incidents and the TCPA regulation is designed to protect the public and the environment. These existing programs exceed the new federal USEPA Risk Management Program requirements in many aspects and have been in place for several years. PolyOne Corporation is also a member of the Chemical Manufacturer's As
sociation and has complied with the codes of practice it has issued for the chemical industry.
PolyOne Corporation has one regulated flammable substance, Vinyl Chloride CAS No. 75-01-4 and one regulated toxic substance, Ammonia (anhydrous) CAS No. 7664-41-7 regulated by OSHA and NJDEP. Vinyl Chloride is used to manufacture dispersion speciality resins. It is polymerized (reacted and converted) into polyvinyl chloride (PVC) which is an inert plastic. This conversion takes place in a closed computerized process using state of the art technology. The product is then dried, packaged and shipped to customers. Ammonia is used as a refrigerant to make chilled water. The chilled water is used to remove heat from the dispersion manufacturing process.
The NJDEP and the USEPA accident prevention regulations require companies to analyze what is defined as a worse-case release scenario. Companies are also required to analyze an alternative release scenario.
se-case scenario is a hypothetical release of the largest quantity of any toxic material or flammable listed under the regulations as determined by USEPA. The USEPA mandates that companies presume the release of the entire quantity of the substance in ten (10) minutes. PolyOne Corporation could not consider the numerous prevention and emergency response systems, procedures, equipment, controls, and trained employees that are in place as part of this scenario.
The alternative case scenario is a more credible scenario that is closer to a real world incident. Facilities are allowed to include active safety systems. Active safety systems include procedures and equipment which are used to contain or minimize the impact of an accidental release. Examples of active safety systems are detection systems, computer controlled valves, fire protection systems and employee actions.
WORST-CASE RELEASE SCENARIO
PolyOne Corporation has one regulated flammable substance: Vinyl Chloride (VCM) CA
S No. 75-01-4
The worse-case scenario assumes the failure of the largest storage tank. This tank has a capacity of 5,000 gallons; however, written operating procedures and high level alarms prevent more than 4,000 gallons from being present at one time. Failure of this tank would release 4,000 gallons (31,000 pounds) of Vinyl Chloride. It is assumed that the entire contents are released within ten minutes and find an ignition source. The result is a vapor cloud explosion. The distance from the source to its endpoint is 0.22 miles. For flammables, the endpoint is the level at which a fire or explosion could damage dwelllings or hurt people. Distance to the endpoint for Vinyl Chloride was found in Table 9 in the USEPA Offsite Consequence Analysis Guidance.
PolyOne Corporation has one regulated toxic substance: Ammonia (anhydrous) CAS No. 7664-41-7
The worst case scenario assumes failure of the largest single heat exchanger. This heat exchanger has a capacity of 1,850 gallons;
however, written operating procedures and high level alarms prevent more than 650 gallons from being present at one time. Failure of this heat exchanger would release 650 gallons (3,500 pounds) of ammonia. It is assumed that the entire contents are released within ten minutes. The distance from the source to its endpoint is 1.2 miles. For toxic materials, the endpoint is the chemical concentration in the air to which a person can be exposed for up to one hour without serious health effects. Distance to the endpoint for Ammonia (anhydrous) was found in USEPA's Guidance for Ammonia Refrigeration Exhibit 4-4 and Figure 4-2.
ALTERNATIVE RELEASE SCENARIO
Flammable Substance: Vinyl Chloride (VCM) CAS No. 75-01-4
The alternative release scenario is a gasket leak at a pipe or valve flange connection equivalent to a 1/4" hole. The leak is isolated within ten minutes. A leak rate of 80 pounds per minute would result in a release of 800 pounds over ten minutes. Unconfined vapor travel
s to the lower flammability limit (LFL). The distance to the endpoint for the LFL is less than 0.06 miles. Distance to lower flammability limit (LFL) for Vinyl Chloride was found in Table 20 in the USEPA Offsite Consequence Analysis Guidance.
Toxic Substance: Ammonia (anhydrous) CAS No. 7664-41-7
The alternative release scenario is a gasket leak at a pipe or valve flange connection or a corrosion hole in piping equivalent to a 1/4" leak. The leak is isolated within ten minutes. A leak rate of 100 pounds per minute would result in a release of 1,000 pounds over ten minutes. The distance to the endpoint is 0.2 miles. Distance to the endpoint for Ammonia (anhydrous) was found in USEPA's Guidance for Ammonia Refrigeration Exhibit 4-5 and Figure 4-3.
There are several tiers or layers of mitigation systems in place at PolyOne Corporation. First and foremost is the PolyOne Corporation Policy and committment to excellence in the areas of Safety, Health and En
vironmental Compliance. PolyOne Corporation has built a strong reputation fulfilling this committment at the Federal, State and local level and with its own employees and contractors. Second are the fourteen key elements of the PolyOne Corporation program. Adherence to these elements is further demonstration of Geon's committment to excellence. Third are the specific mitigation measurements associated with regulated materials that PolyOne Corporation has in place. These include dikes, curbs, impervious containment, detection systems, automatic controls, isolation valves, on site wastewater treatment and back-up systems. Fourth is the site comprehensive emergency response program discussed below. Finally, it is PolyOne Corporation's committment for continued improvement in all covered process areas.
The PolyOne Corporation has in place an approved Risk Management Program for Ammonia encompassing prevention elements consistent with the New Jersey Toxic Ca
tastrophe Prevention Act (TCPA) Title 13, 1B-3. PolyOne also has an approved plan under the New Jersey Spill Compensation and Control Act (DPCC) (N.J.S.A. 58:10-23.11) for both Ammonia and Vinyl Chloride. Additionally, PolyOne has a structured program under the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM) for Highly Hazardous Chemicals (29 CFR 1910.119) for Vinyl Chloride. Vinyl Chloride is also regulated under the OSHA Vinyl Chloride Standard (29CFR 1910.1017) and the USEPA National Emission Standard for Hazardous Air Polutants (40 CFR Part 61 Subpart F 61.60). The same substances that are regulated under the United States Environmental Protection Agency 40 CFR Part 68 Accidental Release Prevention Requirements: Risk Management Programs (RMP) under the Clean Air Act Section 112(r)(7) are also regulated under one or more of these existing programs and their subsequent regulations.
PolyOne Corporation has implemented the following p
revention elements as part of these programs:
1. An Employee Participation policy to regularly consult with employees regarding the development and implementation of prevention program elements and hazard assessments.
2. A comprehensive Process Safety Information program which ensures complete and accurate written information concerning process chemicals, process technology and process equipment. This information is included in the employee training programs.
3. A Process Hazard Analysis is conducted to identify and analyze the potential hazards associated with the processing or handling of highly hazardous chemicals.
4. An Electrical Classification system to ensure properly designed electrical distribution systems in all chemical process areas.
5. The preparation of written Operating Procedures which describe tasks to be performed, operating conditions to be maintained, data to be recorded, and safety precautions to be taken to ensure safe operation of equipment.
Training programs to ensure that all employees involved with chemicals, fully understand the requirements to safely operate each chemical process. The PolyOne Corporation has an "Operator Certification" program in place to train, test and certify all company employees who operate a chemical process.
7. A Contractor program to ensure that they have the appropriate job skills, knowledge and certifications to perform the job safely.
8. For new or modified processes, a Pre-Startup Safety review is conducted to ensure a safe transition into the normal operating mode.
9. A Mechancial Integrity / Preventive Maintenance program designed to continually review and ensure the integrity of all critical operating process equipment, process support utilities and instrumentation.
? Identification and categorization of equipment and instrumentation
? Inspections and tests
? Establishment of prescribed inspection frequencies
? Development and application of pertinent maintenance procedures
? Training of maintenance personnel
? Documentation of test and inspection results
? Documentation of manufacturer's maintenance recommendations
10. A Hot Work Permit system to manage welding, cutting, brazing or spark producing operations in process areas.
11. A Management of Change system to manage changes involving processes, chemicals, technology, equipment or facilities.
12. An Incident Investigation of a chemical release or "near miss" is conducted by a team of experienced individuals familiar with the process. Recommendations are communicated and implemented as appropriate.
13. A facility Emergency Response program is in place in the event of a chemical release. This program is drilled internally and with the community emergency response personnel on a regular basis. An all hazards Emergency Response program is also in place for the surrounding community and the county. This program is coordinated through the Salem County Office of Emergency Services.
14. Annual Co
mpliance 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 PolyOne Corporation has had no chemical releases which created an emergency situation outside the plant boundaries nor resulted in any deaths, injuries, or significant property damage on site or offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage.
EMERGENCY RESPONSE PROGRAM
The PolyOne Corporation has in place Emergency Procedures for handling accidental releases of chemicals. A notification system is in place to initiate response to any emergency. Key personnel are notified by a system of alarms, radios and pagers. Once this notification system is activated, a series of emergency plans is followed by key personnel who are always present on site. For example, in the event of a fi
re, the Emergency Response Team will respond and establish an incident command system sufficient to handle the emergency. The Emergency Response Team is trained to deal with fires, chemical releases, spills and other emergencies. The Emergency Response Team conducts regular training sessions and drills for team members. Some members are trained in First Aid/CPR. Coordinated drills with the Pedricktown and Auburn Fire Departments and the Salem County Office of Emergency Management are conducted annually to ensure good communication and operational effectiveness.
The PolyOne Corporation is an active member of the Salem County Hazardous Material Advisory Council.
PLANNED CHANGES TO IMPROVE SAFETY
PolyOne Corporation will continue to evaluate the regulated process areas under the New Jersey Toxic Catastrophe Prevention Act, the New Jersey Spill Compensation and Control Act, the Occupational Safety and Health Administration Process Safety Management Standard for Highly Hazardous
Chemicals and the United States Environmental Protection Agency Accidental Release Prevention Requirements Risk Management Program to ensure safe operation of its facility.
PolyOne Corporation is proactively involved in several risk reduction activities which include:
? Technology Research
? State of the Art Review
? Best Management Practice
? Inventory Reduction
? Computerized Process Automation
PolyOne Corporation will continue to work with the community emergency management coordinator, fire departments, community officials and County Office of Emergency Management to coordinate training, drills and information.