Para-Chem Southern, Inc. - Executive Summary |
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The Para-Chem site is located on a 125-acre parcel of land near Simpsonville (Greenville County), South Carolina. Para-Chem produces acrylic polymers through water-based emulsion polymerization reactions. This process utilizes a number of chemicals as raw materials, three of which are listed as toxics under 40 CFR 68.130. Two of these chemicals, acrylonitrile and vinyl acetate monomer, are present in quantities above the threshold limits set forth for the RMP program. Furthermore, the process in which these chemicals are used is listed under SIC code 2821, making Para-Chem subject to level 3 program requirements. The RMP requirements can be divided into two main components: 1) development and implementation of a full risk management program, and 2) documentation and submission of a risk management plan that summarizes key information about the program. The full risk management program includes a hazard assessment, a management system, a prevention program, and an emergency respons e program. The risk management plan is designed to present a summary of the risk management program, and the plan will be made available for review by government agencies and the public. Para-Chem must submit risk management information to EPA by June 21, 1999. Acrylonitrile is classified by the USEPA as a toxic. It is handled and stored as a non-refrigerated liquid. Effects of acute exposure to high concentrations of acrylonitrile include irritation of the respiratory tract experienced as nasal discomfort and discharge, with chest pain, coughing, headache, nausea, vomiting, dizziness, and drowsiness. At high doses acrylonitrile can be fatal by inhalation, ingestion, skin contact and other routes. The threshold quantity listed in 40 CFR 68.130 for acrylonitrile is 20,000 lb. Para-Chem uses acrylonitrile as a raw material in an emulsion polymerization reaction and stores a maximum of 38,300 gallons in its monomer tank farm. For modeling purposes, the tank size was rounded to 3 8,500 gallons (258,799 pounds) in order to make conservative estimates. Para-Chem has not had an accident or incident involving a reportable quantity of this material in the last five years. Vinyl acetate monomer is classified by the USEPA as a toxic. It is handled and stored as a non-refrigerated liquid. Effects of acute exposure to high concentrations of vinyl acetate monomer include irritation of the respiratory tract experienced as nasal discomfort and discharge, with chest pain, coughing, headache, nausea, vomiting, dizziness, and drowsiness. Liquid or vapor may cause irritation of the eyes experienced as stinging, excess blinking and tear production, with excess redness in the conjunctiva. At high doses vinyl acetate can be fatal by inhalation, ingestion, skin contact and other routes. The RMP threshold quantity listed in 40 CFR 68.130 for vinyl acetate monomer is 15,000 lb. Para-Chem uses vinyl acetate as a raw material in an emulsion polymerization reaction and stores a maximum of 38,300 gallons in its monomer tank farm. For modeling purposes, the tank size was rounded to 38,500 gallons (299,898 pounds) in order to make conservative estimates. Para-Chem has not had an accident or incident involving a reportable quantity of this material in the last five years. Ammonia is classified by the USEPA as a toxic. It is handled and stored as a non-refrigerated liquid. Effects of acute exposure to high concentrations of ammonia include eye, mucous membrane and systemic irritation by inhalation. At high doses ammonia can be fatal by inhalation, ingestion, and possibly other routes. The threshold quantity listed in 40 CFR 68.130 for ammonia is 20,000 lb. Para-Chem uses aqueous solutions of ammonia in many of its processes but does not store this material in quantities greater than the threshold amount. The threshold quantity calculation for ammonia is based on an example published in the Federal Register: 8,000 gallons * 8.34 lb/gal (H2O) * 0.9 (sp. gr. A mmonia) * 29% active ammonia = 17,414 lb. Ammonia was therefore not evaluated quantitatively but all other safety and operational guidelines apply. Para-Chem has not had an accident or incident involving a reportable quantity of this material in the last five years. Throughout its production processes, Para-Chem uses additional monomers and solvents that are not listed under 40 CFR 68.130 and therefore not subject to RMP requirements. Although many of these materials are hazardous in nature, the relative risk when compared to the listed chemicals is much less. The only accident or incident involving a reportable amount of any of these materials in the last five years was a 700 gallon release of Styrene monomer on April 10, 1997. All of this material was contained on site except for material lost to vaporization, with no injuries or significant property damage resulting from the release. The worst case scenario is a hypothetical release of the largest quantity of any of the haza rdous materials listed under the RMP rule as determined by USEPA. EPA mandates that companies presume a release of the entire quantity of the substance in a ten-minute period. Only passive mitigation efforts, such as controls in place that do not require action by an employee to initiate, are allowed to be considered. Examples of passive mitigation include dikes, berms, enclosures, sumps, and drains that contain or channel a chemical release to a safe location to minimize vaporization. For both Acrylonitrile and Vinyl Acetate Monomer, the worst case event is a complete loss of material from a 38,300-gallon storage tank and subsequent vaporization. The toxic endpoint for acrylonitrile based on Area Locations of Hazardous Atmospheres (ALOHA?) modeling is 0.6 miles. The toxic endpoint for vinyl acetate monomer based on ALOHA? modeling is 0.3 miles. The acrylonitrile radius will affect approximately 500 people including commercial sites, residences and recreation areas. The vinyl ac etate radius will only affect a few commercial sites in the vicinity of the plant. No residential or recreational areas will be affected. The worst case scenario does not allow credit to be taken for the following safety and prevention systems that are in place: ? Relief Valves/Rupture Disks: Prevents overpressurization of a storage tank. ? Maintenance Procedures: Plant and unit-specific procedures for servicing operating equipment. ? Maintenance Training: Knowledge and craft skills necessary to perform routine and complex maintenance tasks on operating equipment. ? Contractor Safety Program: Contractors must satisfy contractor safety program requirements for performing job safely. ? Operating Procedures: Operating procedures details how to safely handle hazardous materials including unloading and transfer procedures. ? Spill Contingency Plan: The Spill Contingency Plan contains detailed information relating to potential failures and methods for containing or cleaning up lost material s. Manufacturing activities are discussed in detail and chemicals are grouped with regard to their physical properties. Emergency contacts are identified and a notification procedure is detailed. ? Emergency Response Training: Plant operating personnel are trained in proper spill response techniques to limit spill quantities and vaporization as well as techniques to neutralize materials. The alternative release analyses considered several different scenarios and evaluated them for most probable failure and greatest consequence. Alternative release scenarios reviewed included the following: ? Transfer hose rupture ? Railcar rupture ? Production transfer piping rupture ? Weigh tank rupture ? Reactor rupture Although all of these are possible events, the most probable and costliest failure would be a transfer hose rupture. This scenario assumes a rupture in one of the transfer hoses during the unloading of a tank car or rail car. Since there are strict procedures for unloading mo nomers, it is assumed that a leak will be recognized and acted upon quickly. The amount assumed to be released is therefore based on the maximum pumping rate of the transfer pump for a period of 30 minutes through a two-inch line. For acrylonitrile this means a 21,720 pound spill with a toxic endpoint of 0.24 miles based on ALOHA? modeling. For vinyl acetate this means a 25,230 pound spill with a toxic endpoint of 0.27 miles based on ALOHA? modeling. Both the acrylonitrile and vinyl acetate radii will only affect a few commercial sites in the vicinity of the plant. No residential or recreational areas will be affected. Para-Chem operates in a manner that attempts to minimize hazards associated with the handling of chemicals. Bulk storage tanks are maintained within containment dikes to control the loss of material due to spills and procedures are in place to address specific potentially hazardous activities including such things as unloading of transfer vehicles and process oper ation. The following are some of the relevant procedures and plans. The Spill Contingency Plan contains detailed information relating to potential failures and methods for containing or cleaning up lost materials. Manufacturing activities are discussed in detail and chemicals are grouped with regard to their physical properties. Emergency contacts are identified and a notification procedure is detailed. ? All plant operating personnel are required to notify their immediate supervisor in the event of an emergency. ? The supervisor will then contact the plant Emergency Coordinator (EC). ? The EC will then contact plant management. ? Plant Management will contact the appropriate local, state and federal officials. A call list designating these contacts is provided in the Spill Contingency Plan. A copy of the Simpsonville Spill Contingency Plan is available for review at the site. Para-Chem regularly receives bulk shipments of chemicals in tank cars and transfers these materials into bulk storage tanks located in one of several tank farms with secondary containment. The tank trucks are parked in secondary containment areas located by each tank farm and unloaded by trained personnel. Para-Chem has a documented ISO-9001 procedure for these operators to follow which is available for review at the site. Para-Chem regularly receives bulk shipments of chemicals in railcars and transfers these materials into bulk storage tanks located in one of several tank farms with secondary containment. The railcars are parked in designated unloading areas near the tank farm and are unloaded by trained personnel. Para-Chem has a documented ISO-9001 procedure for these operators to follow which is available for review at the site. In the event of severe weather, Para-Chem is dedicated to protecting its employees and the surrounding community. Procedures have been set up to warn plant employees and shut down key operations in order to minimize material loss in the event of a wea ther related failure. The severe weather procedure is available for review at the site. It is Para-Chem's training philosophy that all employees will be trained to perform their assigned duties safely and effectively. To this end, ISO procedure TG-100 was created to provide work instructions and training documentation tools for effectively and systematically planning training initiatives, assessing training needs, providing required employee training, and maintaining appropriate training records. A copy of this procedure is available for review at the site. In order to ensure an efficient workplace, preventive maintenance is performed on a majority of the equipment at Para-Chem. These procedures are documented and a copy of the related ISO procedure is available for review at the site. Although every effort is made by Para-Chem to conform to all governmental agency policies and regulations, it is possible that some are overlooked. Because of this, Para-Chem has retained the ser vices of The Fletcher Group, an environmental consulting firm located in Greenville, SC., to provide periodic environmental compliance audits. The results of these audits are then used to ensure that Para-Chem operates in a safe and compliant manner. Safety is of utmost concern in any facility that handles hazardous chemicals. At Para-Chem it begins on day one with our new employee training. New employees are taught the basics of hazardous materials safety, hazard communication and fire and emergency evacuation procedures as well as specific job related tasks. Key activities such as loading and unloading of tank trucks and railcars are given documented procedures to minimize the risk of accidents. Several of these have been documented in Section 4. Additionally, a copy of the basic safety rules that all employees must abide by is available for review at the site. Although the Simpsonville location employs over 150 people, it is sometimes necessary to bring in outside contractor s for specific tasks. Any contractor that is performing work in the manufacturing facility is given a safety briefing that includes: ? Emergency Evacuation Plan ? Location of Fire Extinguishers, Fire Exits, and Eye Wash/Shower Stations ? Location of MSDS ? Location of Safety Manuals ? Specific Hazards Workers May be Exposed To ? Use of PPE ? Requirements of Hot-Work Permits ? Use and Storage of any Flammable Liquids ? Location of any Underground Utility Lines ? Manner of Conduct ? Other related information It is evident from this review that the manufacture of specialty chemicals poses some risk to the public due to the nature of the raw materials used. Para-Chem has taken every effort to minimize these risks by implementing programs and procedures which reduce the possibility of incidents involving the storage and handling of these chemicals. |