Franklin International - Polymer Division - Executive Summary |
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EXECUTIVE SUMMARY Franklin International is an adhesives and sealant manufacturer with its headquarters, research laboratories, and primary manufacturing facilities located in Columbus, Ohio. There are four separate divisions at the Bruck street site comprising approximately 180,000 square feet of building on fourteen and one half acres. Vinyl Acetate monomer is a major ingredient in the production of the polymer suspension used in many of our products. Vinyl Acetate monomer is listed on Environmental Protection Agency's (EPA) toxic substance list because of its ability, at certain concentrations, to form toxic vapors in air. Franklin has taken several measures to prevent public exposure to these vapors. The raw material is shipped in liquid form and is immediately transferred to underground storage tanks per Department of Transportation (D.O.T.) regulations. The transfer equipment uses a closed loop system with vapor recovery devices, which minimize the discharge of hazardous vapors to the air. This system has been upgraded in the last five years as a result of hazard analyses done on our unloading processes. In addition, Franklin personnel are required to be in the immediate area supervising the unloading of each shipment and are trained in proper unloading procedures and emergency procedures. Vinyl Acetate is transported through closed piping systems to the various process vessels in the facility. Mechanical systems on the transfer pumps limit the amount of material that would be released in the event of a piping failure. The EPA has defined two scenarios that must be evaluated for each covered process. The worst-case scenario must be an event that affects the largest area around the facility. Wind speeds and weather conditions prescribed by the EPA must be used in the scenario. The worst-case scenario does not allow any consideration of the likelihood of the event. This means that the worst-case scenario may affect a large area but the likelih ood of this type of incident occurring could be so low that the facility and those around it are extremely safe. The alternative scenario is defined as an event that may occur based on good engineering judgement or past history. The alternative scenario must affect an area outside the facility boundaries to be used in this analysis. The worst-case scenario for our covered process is the complete failure of a full railcar of Vinyl Acetate at our facility. Since the railcar is placed on a rail siding, no passive mitigation (physical systems that will keep the release from spreading) is included in the analysis. Our worst case analysis shows an offsite impact with both public and environmental receptors (schools, churches, state parks, rivers) being affected. However, it is worth noting that the worst case scenario presented here is extremely unlikely to occur. The railcars used to transport Vinyl Acetate are designed and built to strict DOT codes, which apply conservative safety f actors to all critical construction details. The possibility of a total railcar failure is highly unlikely. The alternative scenario selected for our process is a failure of a fitting on one of our process vessels containing Vinyl Acetate. Although this type of incident has never occurred at our facility, it is the most credible scenario that may affect off-site populations. The building surrounding the process vessel was considered as passive mitigation (a physical structure that will keep the release from spreading). Although this scenario did affect areas outside Franklin property, the impact is minimal. No environmental receptors (state parks, rivers, etc...) were affected; however residents within a one-city block radius may be impacted. In order to prevent serious release of a hazardous chemical, Franklin International maintains a proactive approach to environmental, health and safety. Upholding the safety and health of our team members, customers, and neighbors in the co mmunity is among our eight corporate values. Our facility complies with the Occupational Safety and Health Administration's Process Safety Management standard and our employees undergo extensive training to prepare them for the hazards of the chemicals they work with. Franklin utilizes detailed operating procedures and checklists to ensure the safe operation of all process equipment on site. Where feasible, process controls and interlocks are used to prevent accidental releases. We feel the fact that we have had no accidental releases of Vinyl Acetate, as defined by EPA's Risk Management Program, is a direct result of the safety programs we have in place. Franklin International has employees trained for response to hazardous material releases and, as a backup, has contracted with an outside firm who is capable of responding to large chemical releases. In addition, we have coordinated with local emergency response units and share information about our facility layout and hazardo us chemicals on site with them on a regular basis. We periodically conduct evacuation drills and mock emergencies to maintain a high level of awareness among our employees. Currently, our operators are being phased through a certification and training program that reinforces safe operating practices and emergency procedures. In summary, Franklin International is dedicated to providing a safe environment not only for our employees but also for our neighbors in the community. Capital funds are appropriated every year to strengthen our safety and environmental programs and implement continuous improvement projects and process hazard analysis recommendations. In the process of complying with our federal air permits, we monitor our process emissions to protect the environment. Franklin is committed to addressing any concerns in a timely manner, and maintains communication with the community through local citizen groups. |