BFGoodrich Performance Materials Cincinnati Plant - Executive Summary |
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THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED The BFGoodrich Performance Materials Plant in Cincinnati is a specialty chemical manufacturing plant located nine miles north of Cincinnati's downtown business district on a 72- acre tract surrounded by light industry and residences. We manufacture more than 100 chemical products, 75 percent of which are consumed in the U.S. and the rest are sold on the international market, contributing significantly to the U.S. gross national product. Our products include colorants and chemicals used to produce pigment dispersions for paints and inks, dyes for technical applications and food colors, and specialty products including dyes used in pressure-activated or heat-activated business papers. We have been doing business in Cincinnati since 1922. We have 380 employees with an annual payroll of $20 million, paying about $405,000 in city taxes and $2 million in county taxes annually. Each year, we buy about $8.1 million in goods and services , mainly from local suppliers, and pay about $4.3 million for utilities and $ 2.5 million for freight services. Our plant uses two chemicals as raw materials that bring us under the EPA Risk Management Program (RMP) Rule. These are oleum and a solution of formaldehyde in water, each of which is classified as a toxic under the RMP. The types of programs recently required by the RMP to prevent serious accidents and to plan emergency contingencies have long been in place at our plant. We have long understood the relationship between good safety and environmental performance and good business. Nevertheless, we welcome the EPA's RMP initiative and see it as an opportunity to continue and expand dialog with our community. THE ACCIDENTAL RELEASE PREVENTION PROGRAM AND EMERGENCY RESPONSE POLICIES AT THE STATIONARY SOURCE It is the policy of BFGoodrich to meet or exceed all requirements established by applicable safety, health and environmental regulations promulgated by Federal and State ag encies. Our safety policies and practices have historically preceded the regulation of such practices under, for example, the OSHA Process Safety Management Standard and the EPA Risk Management Program Rule. Since before the acquisition of our plant by BFGoodrich, it has been our policy to maintain at a practical minimum the potential for harm to on-site employees and contractors, the public, and the environment, and to have in place contingency actions, coordinated with local responding agencies, for the unlikely event of a serious accidental chemical release. The success of this policy is exemplified by having received the Greater Cincinnati Chamber of Commerce Corporate Environment Award. Since our acquisition by BFGoodrich, we are committing even greater resources to consolidating and improving further our safety and environmental performance. A related program in which we participated was a company-wide Y2K effort to ensure that Y2K issues associated with our computer-based syste ms and those of our suppliers did not impact the safety and environmental performance of our operations. Another safety and environmental-related program in which we participate is Responsible Care? under the Chemical Manufacturer's Association, a six-code voluntary program with strong emphasis on process safety and pollution prevention. We also expect to be certified under the ISO-9000 international quality standard, a set of quality management systems that include safety, by early year 2000. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We have in place a thorough, ongoing program of process safety management (PSM). This program calls for implementation and maintenance of procedural and engineered safeguards at the plant to minimize the likelihood of a significant release of a hazardous chemical, and to eliminate or reduce the effects of any release that might occur. We have invested and continue to invest substantial effort and capital i n maintaining our strong safety and environmental performance. Some recent examples of our investments include the construction of a waste handling and recycling facility at a cost of $300,000, improvements in our safety management program at a cost of $200,000, and the introduction of an employee safety incentive program. We are involved in day-to-day safety-focused activities under our program that include elements such as: (1) Process Hazard Analyses - we routinely perform and maintain up to date, systematic and thorough studies of our operations to identify what could go wrong, identify means of eliminating or reducing design or procedural weaknesses, and implementing improvements. (2) Process Design - our processes and equipment are designed for safety in accordance with applicable industry standards and best engineering practices. Designs include, as appropriate, emergency shutdown systems, pressure relief devices, ventilation systems, and release sensoring systems. Our storag e vessels, which contain the greatest inventories of hazardous chemicals, are contained in concrete dikes and mainly indoors. (3) Training - our operations and maintenance personnel are trained thoroughly on their job tasks, on safe work practices as they apply to their jobs, and emergency contingency actions, before they may operate or maintain equipment. They also receive refresher training periodically. Our procedures for operating and maintaining processes, general safe work practices, and emergency response, are fully documented and maintained up to date in light of any changes at the plant. (4) Maintenance - Each item of equipment at our plant that is involved in maintaining safety or in responding to an abnormal situation is inspected, tested and/or maintained on a frequency that reflects its service and condition. (5) Management of Change - no change to equipment or procedural practices can take place at the plant without a thorough review of the implications of that change to safety. No change must adversely impact the safety built into the design and operations of our processes. Our PSM program is tuned to reflect the specific hazards of the chemicals we use. For example, our operating, maintenance, safe work, and emergency procedures address personal protective equipment appropriate to the chemicals being handled. Also, equipment is selected based on its intended service and chemical exposures, including release detection devices. THE FIVE-YEAR ACCIDENT HISTORY We have had one event at our plant that qualifies for inclusion in the RMP 5-year accident history. This involved an indoors leak of oleum within the plant. The event resulted in no harm to any individual or to the environment. The event qualifies for the 5-year history only by virtue of the precautionary measures that were taken after the spill. THE EMERGENCY RESPONSE PROGRAM We have in place a written emergency response plan that we coordinate with the Hamilton County Local Emergency Pla nning Commission, the Cincinnati, Golf Manor, and Norwood Fire Departments, the Metropolitan Sewer District, and other local responders. New personnel are trained on the plan, we conduct refresher training annually, and we train on any revisions to the plan. The plan is in compliance with the RMP requirements, as well as other applicable EPA and OSHA requirements. PLANNED CHANGES TO IMPROVE SAFETY Our safety program is ongoing, involving the identification and implementation of numerous means of incremental safety performance. THE WORST-CASE RELEASE SCENARIOS AND THE ALTERNATIVE RELEASE SCENARIOS The RMP provides a detailed prescription for what should be considered a worst case scenario (WCS). Under that prescription we have identified a WCS. It involves a large indoors spill of oleum. Based on use of the EPA Offsite Consequence Analysis Guidance, this scenario is calculated to have offsite impacts. More credible scenarios, called alternative release scenarios (ARSs), were also analyzed. As required by the RMP Rule, we chose hypothetical ARSs that are severe enough to have effect beyond our fenceline. The selected ARSs are highly unlikely scenarios of the type our process safety management program protects against. Our ARSs involve the rupture of a flexible hose during the transfer of raw materials (formaldehyde solution or oleum) from the delivery tanker into a storage vessel. The spilled liquid begins to evaporate resulting in the production of vapor which, based on the use of EPA modeling tools, is predicted to have impact beyond our fenceline. The hypothetical formaldehyde spill is predicted to disperse marginally beyond our fenceline with no effect on the public. The oleum spill is predicted to disperse about 0.3 miles from the tanker - up to about 420 yards beyond our fenceline. There are several safeguards that protect against these scenarios occurring. First, our procedures require that the hoses be thoroughly checked before the hose is used to tran sfer liquid. Second, we pressure test each flexible hose before it is used to transfer a hazardous material. Any leaks or poor connections would be detected during the pressure test. Third, because our operating procedures require an operator to be present during unloading, the operator would in reality turn off the transfer pump within seconds, not minutes (as assumed to achieve an offsite impact, per RMP Rule specifications) of a spill occurring. We expect scenarios such as these ARSs to continue to be highly hypothetical and unlikely due to our ongoing program of process safety. |