HERCULES INCORPORATED - PARLIN PLANT - Executive Summary |
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Executive Summary - Hercules Parlin RMP submittal. Policy: Hercules Incorporated is a member of the Chemical Manufacturers Association and is committed to the principles of Responsible Care ?. The Corporate Policy on Safety, Health and Environment states: At Hercules, we manufacture chemical specialty products. We do so with full commitment to the chemical industry's Responsible Care? initiative. In keeping with this commitment, we are dedicated to providing a safe and healthful environment for our employees, customers, and communities. To do this, we are dedicated to and working toward continuous improvement in our operations to prevent pollution; to reduce risk; and to enhance safety, health, and environmental performance. By incorporating these beliefs and attitudes into the way we do things at Hercules, we take a key step forward in minimizing the environmental impact of our operations, satisfying customer needs, and creating shareholder value. We will adhere to the following b asic principles in managing our business worldwide: We will comply with the letter and spirit of all applicable safety, health, and environmental laws, regulations, and corporate guidelines. We will define strategic objectives, develop tactical plans, identify clear accountability, provide necessary resources, and measure our progress on safety, health, and environmental matters on an ongoing basis. Our planning will consider both business goals and significant safety, health, and environmental aspects of our products and operations. We will evaluate the safety, health, and environmental impacts of new and existing products and operations and will work to reduce the adverse impacts. We will provide for an open dialogue on safety, health, and environmental issues relating to our products and operations with our stakeholders, including shareholders, employees, customers, suppliers, government agencies, and communities. We will work to continually reduce workplace injuries; incidents with the potential for causing property damage, material loss, or interruption of our business; waste; and releases to the environment. We will emphasize product stewardship and advocate its importance to our suppliers, distributors, and customers. Facility Description: The primary activity at the Parlin Plant is the manufacture of Natrosol? (hydroxyethyl cellulose). Natrosol ? is used as a thickener in latex paint and personal care products. The primary ingredients in Natrosol ? are cellulose (wood or cotton linter fiber) and ethylene oxide. Ethylene oxide is received in 25,000-gallon railroad tank cars and stored in two tanks, each limited to 27,000 gallons by administrative controls. The ethylene oxide unloading and storage area is provided with containment dikes and pits in which a spill can be diluted with water. This facility is also equipped with leak detectors and fixed water spray nozzles to minimize any adverse impacts if there were a spill. Worst Case Scenario: The worst case scenario for the plant is the failure of an entire storage tank, containing 27,000 gallons (195,000 pounds) of ethylene oxide. This scenario will have an offsite impact, based on the use of the SLAB model . This scenario is based on the EPA required assumption for toxic gases that the tank contents will flash to vapor in 10 minutes. Because the boiling point of ethylene oxide is close to ambient conditions, the material will not completely vaporize in 10 minutes, instead, a liquid pool will form and the ethylene oxide will evaporate, as well as flash. When this, more realistic scenario is modeled, the offsite impact is reduced significantly. In addition, this scenario requires the extremely unlikely event of a catastrophic failure of the storage tank. Administrative controls in standard operating procedure and high level alarms limit the quantity released in this scenario. Alternative Case Scenario: The alternative case scenario for ethylene oxide is a discharge of 3,900 p ounds of vapor from a relief valve that fails to close. This scenario will have an offsite impact, based on the use of the EPA OCAG guidance. The impact from this scenario is limited by the design, which incorporates a multi-port valve that can be re-positioned to isolate the failed valve and place another in service. Accident Prevention Program: The use of ethylene oxide in the plant's processes has been subject the New Jersey Toxic Catastrophe Prevention Act (TCPA) regulations since their adoption in 1988, as well as the subsequently adopted OSHA Process Safety Management standard (29CFR 1910.119). The plant has an established risk management system in place to meet these requirements and to minimize the potential for accidental release of these substances. Our management system includes: 1. Process hazard analysis to identify and address potential hazards. 2. Management of change procedures to assure that standards are maintained and potential new hazards assessed. 3. Mechanical integrity procedures for minimizing mechanical failures, Detailed operating procedures for process control 4. Training for the personnel involved in operating and maintaining the processes. 5. Facility design incorporates multiple layers of incident prevention. Five Year Accident History: In the past five years, the Parlin plant has not had any accidental releases of ethylene oxide that resulted in on-site injuries or damage or any off site impacts. Emergency Response Program: The Parlin plant has a written emergency response plan and coordinates emergency response matters with the Sayreville Office of Emergency Management (L.E.P.C.). The plant provides emergency response training for all plant employees and has trained emergency response teams on site. Emergency response exercises are conducted several times each year. |