Asahi Glass Fluoropolymers, inc. - Executive Summary |
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EXECUTIVE SUMMARY REVISION- RMP SUBMIT 2000 Abstract The following is the Executive Summary of the Accidental Release Program at Asahi Glass Fluoropolymers, Inc. USA As required under US-EPA 40 CFR 68.155, it outlines the following aspects of Accidental Release Prevention at our facility: 68.155(a):The accidental release prevention and emergency response policies; 68.155(b):The stationary source and regulated substances handled; 68.155(c):The worst-case release scenarios and the alternative release scenarios for each regulated toxic and flammable material subject to regulation; 68.155(d):The general accidental release prevention program and chemical-specific prevention steps 68.155(e):The five-year site accident history 68.155(f): The Emergency Response Program 68.155(g):Planned changes to improve safety 40 CFR 68.155(a): Site Release Prevention and Emergency Response Policies Asahi Glass Fluoropolymers, Inc. USA ("AGF-Bayonne") has implemented an Accidental Release Prevention Program which includes Process Safety Information according to a documentation plan. Process Hazard analyses are conducted on a five-year schedule by a process hazard analysis team, using HAZOP techniques. The team is composed of a HAZOP Team Leader, Process Supervisors, Process Operators, Maintenance Personnel and other personnel familiar with site production and safety. Results of these Hazard Analyses have been recorded on the HAZOP 1, 2 and 3 ProFormas. Recommendations resulting from these HAZOPs are recorded, assigned to specific personnel and tracked by the Process Safety Supervisor. Operating Procedures are written by process supervisors, operators and others with input from all affected parties. These Operating Procedures are reviewed by representatives of the site Safety, Health and Environment; Site Management; Site Production Management, Site Engineering; and Research & Technical Departments before they are adopted into the site's Catalogue of Standard Operating Procedures. Operating procedures are maintained and are available on local computer networks on a read-only basis. Any changes to Operating Procedures must be made via the site's Management of Change Procedure, where they are reviewed by the above noted departments before adoption onto the site's computer network. 40 CFR 68.155(b) Site Description and Regulated Substances Handled AGF-Bayonne occupies approximately 34.5 acres in the Constable Hook area of the city of Bayonne, NJ, a heavily industrialized area bordered on three sides by New York Bay. The site employs 137 full-time staff and one part-time employee. The site manufactures only one product, polytetrafluoroethylene, an adhesion-resistant plastic used in numerous consumer, medical and industrial applications whose trade name is Fluon. The regul ated substances handled at the site are approximately eighteen thousand pounds of Anhydrous Ammonia, CAS # 7664-41-7 which is used as a refrigerant gas in the site's refrigeration and chiller system; thirty thousand pounds of Tetrafluoroethylene, CAS # 000116-14-3, a raw material which is polymerized to form Fluon; and one hundred and twenty thousand pounds of Aqueous Ammonia, 26% by weight, CAS # 7664-41-7 which is utilized in the plant's Wastewater Treatment system. 40 CFR 68.155 (c): Worst-Case and Alternate Release Scenarios The Worst Case Release Scenario ("WCS") for Anhydrous Ammonia is estimated to reach a Toxic Endpoint of 1.4 miles, determined using the Lookup Table sin the EPA OCA Guidance Document. This may result in impacts on public receptors within the city of Bayonne and possibly Staten Island. Diking of the bulk Ammonia receiver is used as passive mitigation. The WCS for Tetrafluoroethylene is expected to reach a 1 psi overpressure at 260 feet from the source point. While this technically crosses the site's nearest property line, it is not expected to have any appreciable offsite impact. The WCS for Aqueous Ammonia will result in a Toxic Endpoint at approximately 0.05 miles, and is not expected to any appreciable offsite impact. Diking of the Bulk Storage tank is used as passive mitigation. The Alternate Scenario ("ACS") for Anhydrous Ammonia is predicted via dispersion modeling to reach a Toxic Endpoint of 0.33 miles at 15 minutes into the release. This ACS was based on a catastrophic failure of a Condenser Tube, releasing 2310 pounds of Ammonia over a duration of about 15 minutes, the time believed necessary for in-house response to address the incident. The ACS for Aqueous Ammonia reaches the Toxic Endpoint of .08 miles at 60 minutes. This release was given a duration of two hours , and does not account for mitigation features ordinarily in place. 40 CFR 66.155(d): Accidental Releas e Prevention Program Release prevention steps at the site include relief valves, check valves, manual shutoff systems, automatic control interlocks, alarms, written procedures, direct attendance by process operations personnel, keyed bypasses, emergency air supplies, emergency power systems, grounding equipment, rupture disks, excess flow monitors, alarms and controls, purge systems, and excess pressure and temperature control interlocks. Mitigation systems used are water deluge systems, sprinkler systems, firewalls, and neutralization systems. The process areas are monitored by a system of continuous leak detection "sniffer" systems, which are interlocked with readouts and alarms in the production Control Room. Operator initial and refresher training is actively revised and reconducted as changes to these and other production systems are made. This retraining is encompassed within the site's Operator Training program. All Release Prevention, Mitigation and area sniffer systems are subject to the site's Preventative Maintenance program. Equipment reliability information is used in scheduling routine inspections and tests of these systems to ensure their uninterrupted operation. The site's Management of Change program, monitored by the ASAHI Safety, Health and Environmental manager, ensures that equipment, process or software changes are not made without the direct input of all affected individuals. All changes are screened by the SHE Manager to determine if further HAZOP studies are required for a particular change. No changes are made which do not conform to corporate standards for safe design and operation. All incidents are investigated to determine root cause and identify any potential system deficiencies requiring correction. 40 CFR 68.155(e) Five-Year Accident History The company experienced one incident involving an regulated substance, Anhydrous Ammonia, on 26 June, 1997. The incident involved a ten -minute release of approximately 1.2 pounds. there were no offsite or onsite impacts. There was no property damage, and there were no injuries. two Action Items were executed in response to an investigation of the incident. 40 CFR 68.155(f) The Emergency Response Program AGF-Bayonne maintains an Integrated Contingency Plan know onsite as the FEPP or Facility Emergency Preparedness Program. The plan defines the structure of AGF-Bayonne's on- site response team, it's coordination with the local emergency response agencies such as the Bayonne OEM which is managed by the Bayonne Fire Department, equipment inventories and locations on site, response procedures, site emergency notification procedures, and emergency response drills. The FEPP is updated as necessary based on results of emergency response drills, response team staffing, or other detail changes. 40 CFR 68.155(g) Planned Changes to Improve Safety While current site control and safety s ystems reflect the "state of the art" for design, it is recognized that safety is a continuing process. To this end, AGF-Bayonne actively maintains a Behavior-Based safety Management program known as "SABRE". Other changes include those items resulting from the latest HAZOP Revalidation, conducted in Fall 1999. |