Air Products Polymers, L.P. - Executive Summary

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Federal RMP Executive Summary 
 
Air Products Polymers, L.P. 
Langley, South Carolina  Emulsions Facility 
 
1.  Accidental release prevention and emergency response policies: 
 
The Air Products Polymers, L.P., facility in Langley, South Carolina contains a RMP covered process, which is an acrylic polymer emulsions manufacturing process.  The facility must maintain greater than 10,000 pounds of acrylonitrile, vinyl acetate monomer and 28% aqua ammonia to safely and efficiently manufacture acrylic polymer emulsions. There are currently no RMP flammable materials above the action threshold.  
 
It is our policy to adhere to all applicable federal, state, and local rules and regulations as well as our own environmental, health, and safety standards.  Air Products manages the safety of our facility by designing for safe operation, operating and maintaining the plant safely and by auditing our operations. Our accident prevention program is based on OSHA?s Process Safety Management regulation and ou 
r emergency response program is based on OSHA?s HAZWOPER regulation. 
 
Air Products is committed to continuous improvement in all aspects of safety and environmental performance.  Air Products is a member of the Chemical Manufacturer?s Association and subscribes to the Responsible Care Program.  The Langley facility is actively involved with local organizations concerned with the safety of our community and the environment such as the Aiken County Local Emergency Planning Committee (LEPC), Aiken County HAZMAT and the Air Products, Langley Plant, Community Advisory Panel. 
 
2.  The facility and the regulated substances handled: 
 
The Air Products Polymers, L.P. acrylic polymer emulsions manufacturing facility is located at 403 Carline Road, Langley, South Carolina.  To produce acrylic polymer emulsions, acrylate monomers and acrylonitrile liquids are polymerized in reactors to form acrylic polymer emulsions.  The acrylic emulsion is a non-hazardous, water based liquid.  The product is then 
shipped by bulk trucks, totes and drums to industrial customers for the production of graphic arts ink additives, paper coatings and adhesives.  Approximately 40,000 pounds of acrylonitrile, 120,000 pounds of liquid vinyl acetate monomer, and 75,000 pounds of 28% aqua ammonia is present on site in the storage tanks, piping and processing. 
 
3.  The worst case release scenario(s) and the alternative release scenario(s): 
 
The worst case release scenario for an RMP listed toxic liquid at the Langley, SC facility, as defined by the EPA, involves the release of acrylonitrile from the failure of an acrylonitrile tank truck while unloading. The spill pool from a bulk tank truck failure is larger than that from the failure of our bulk storage tank due to passive mitigation, and therefore results in a higher release rate, giving a more distant toxic endpoint.  The tanker failure event would have off-site impact.  The EPA Offsite Consequence Analysis Guide was used to determine what off-site imp 
act would result in the event of this release, which would involve approximately 20,000 pounds of material.  The worst case release scenario is highly unlikely due to several factors which include required operator presence in the field to watch for leaks or spills while unloading the material, and passive mitigation, which limit both pool size and the vaporization of the release. 
 
The alternate case scenario for acrylonitrile at our facility is the failure of a hose while unloading acrylonitrile to a storage vessel in the manufacturing facility.  This scenario could result in the release of 5,400 pounds of acrylonitrile.  Although there have been no instances of a release of this magnitude at the Langley site, we have experienced small leaks around hose flanges which indicate that this scenario might be possible and would be reasonable for emergency planning purposes.  This release has been estimated to barely reach off-site of our facility. 
 
The alternate case scenario for vinyl acet 
ate at our facility is the failure of a hose while unloading acrylonitrile to a storage vessel in the manufacturing facility.  This scenario could result in the release of 933 pounds of vinyl acetate.  This release has been estimated to barely reach off-site of our facility. 
 
The alternate case scenario for aqua ammonia at our facility is the failure of a hose while unloading acrylonitrile to a storage vessel in the manufacturing facility.  This scenario could result in the release of 875 pounds of aqua ammonia.  This release has been estimated to barely reach off-site of our facility. 
 
4.  The general accidental release prevention program and specific prevention steps: 
 
Our accident prevention program is based on OSHA?s Process Safety Management regulation.  Air Products manages the safety of our facility by designing for safe operation, operating and maintaining the plant safely and by auditing our operations. 
 
Our facility is designed for safe operation through the use of emergency 
shutdown systems and alarms, automatic water deluge systems, fail-safe valves, and dikes for the unlikely case of a potential leak.  Systems and equipment are designed  to engineering standards and codes. Safety reviews are conducted prior to all projects and changes.   
 
Our plant is operated safely by trained and certified operators who follow well maintained standard operating procedures with defined safe operating limits.  Routine process safety meetings are held for all personnel. Investigations are conducted for all incidents. 
 
We maintain operational safety through preventative maintenance and equipment inspection programs.  We hold contractors to the same high safety training standards as our employees.  We utilize task observations and accident prevention techniques on jobs. 
 
We routinely audit our operations for compliance with federal, state, and local regulation.  We also have a comprehensive program to audit the plant?s performance against corporate environmental and safet 
y standards. 
 
5.  Five year accident history: 
 
There have been no releases of acrylonitrile, vinyl acetate monomer, or 28% aqua ammonia at the Air Products Polymers Plant, Langley, SC,  in the past five years that have had an adverse impact on the community.  There have been no incidents at the facility that meet the EPA Risk Management Program reporting requirements. 
 
6.  The emergency response program: 
 
The facility?s emergency response program is based upon OSHA?s HAZWOPER standard.  At this site, employees are trained to recognize emergencies and initiate emergency response from outside agencies.  They have been trained to OSHA?s First Responder Awareness Level.  The employees receive annual refresher training in their role in the emergency plan.  Emergency response activities have also been coordinated with the Aiken County LEPC and Langley Volunteer Fire Departments for awareness on potential hazards and locations of materials at the site.  
 
7.  Planned changes to improve safety: 
 
 
Although we have no current plans to install new mitigation, control equipment nor to change technology, we are constantly striving for continued improvement in all aspects of environmental and safety performance.  Process safety is evaluated regularly through conducting operational plant hazard reviews and studying incidents which have occurred within the chemical industry.
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