W. R. Grace & Co -- CONN, Darex Specialty Polymers - Executive Summary |
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General Executive Summary For W. R. Grace & Co -- CONN, Darex Specialty Polymers Owensboro, Kentucky Site 1. Accidental Release Prevention and Emergency Response Policies We at W. R. Grace & Co -- CONN, Darex Specialty Polymers are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our well trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also coordinated with the Local Emergency Planning Committee (LEPC/Daviess County Sheriff's Department) which provides additional emergency response expertise. 2. The Stationary Source an d the Regulated Substances Handled Our facility's primary activities encompass the production of various latex polymers, which falls under Standard Industrial Classification ("SIC") Code 2821. We have six regulated substances present at our facility. These substances include 1,3-Butadiene, Acrylonitrile [2-Propenenitrile], Vinyl acetate monomer [Acetic acid ethenyl ester], Vinylidene chloride, and a 20%, 2-4 and 80% 2-6, isomeric mixture of Toluene diisocyanate. The regulated substances at our facility are involved in several uses. 1,3-Butadiene, acrylonitrile, vinyl acetate and vinylidene chloride are used for manufacturing liquid latex emulsion polymers. Toluene diisocyanate is used for manufacturing polyurethane prepolymers. The maximum inventory of Vinyl acetate monomer [Acetic acid ethenyl ester] at our facility is 500,997 lb. while Vinylidene chloride [Ethene, 1,1-dichloro-], 1,3-Butadiene, Acrylonitrile [2-Propenenitrile], Toluene 2,6-diisocyanate [Benzene, 1,3-diisocya nato-2-methyl-] and Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl-] are present at our facility in quantities of 407,100 lb., 275,000 lb., 133,357 lb., 56,979 lb. and 14,245 lb. respectively. 3. The Worst Case Release Scenarios and the Alternative Release Scenarios, including administrative controls and mitigation measures To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from Vinyl Acetate. In this scenario 467,374 lb. of Vinyl acetate monomer [Acetic acid ethenyl ester] is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 2,015 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, t he maximum distance of 1.9 miles is obtained corresponding to a toxic endpoint of 0.26 mg/L. The alternative release scenario for Vinyl acetate monomer [Acetic acid ethenyl ester] involves the release of 233,687 lb. of toxic liquid from the Vinyl Acetate storage tank and is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 587 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.26 mg/L of Vinyl acetate monomer [Acetic acid ethenyl ester] is 0.51 miles. The alternative release scenario for Acrylonitrile [2-Propenenitrile] involves the release of 82,066 lb. of toxic liquid from the Acrylonitrile storage tank and is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 2,214 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.076 mg/L o f Acrylonitrile [2-Propenenitrile] is 0.20 miles. The alternative release scenario for Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-methyl-] involves a release from Toluene Diisocyanate. The scenario involves the release of 48,025 lb. of toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 8,829,951 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0070 mg/L of Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-methyl-] is 0.10 miles. The alternative release scenario for Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl-] involves a release from Toluene Diisocyanate. The scenario involves the release of 12,006 lb. of toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 2,207,488 minutes. Under neutral weather c onditions, the maximum distance to the toxic endpoint of 0.0070 mg/L of Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl-] is 0.10 miles. The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from Butadiene. In this scenario 247,698 lb. of 1,3-Butadiene is released. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.50 miles is obtained corresponding to an endpoint of 1 psi overpressure. One alternative release scenario submitted for Program 3 flammable substances involves a release from Butadiene. The release is assumed to result in a BLEVE. The scenario involves the release of 125,100 lb. of 1,3-Butadiene. Passive mitigation controls such as a sprinkler system are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 is 0.43 miles. Another alternative release scenario submitted for Program 3 flammable substances involves a release from Vinylidene Chloride. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 203,496 lb. of Vinylidene chloride [Ethene, 1,1-dichloro-]. Passive mitigation controls such as a sprinkler system are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 is 0.19 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is subject to EPCRA Section 3 02 notification requirements and we also have submitted a Clean Air Act, Title V air operating permit application to the EPA for approval. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information W. R. Grace & Co -- CONN, Darex Specialty Polymers maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Some examples of the process safety information include Material Safety Data Sheets (MSDS) on all raw materials and products, Equipment Specification Sheets, and Process Instrumentation and Design drawings (P&ID). Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is Checklist, What If/Checklist (combined) and HAZOP. The st udies are undertaken by a team of qualified personnel with expertise in engineering and process operations. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 06/04/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, W. R. Grace & Co -- CONN, Darex Specialty Polymers maintains written operating procedures. Where applicable, these procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training W. R. Grace & Co -- CONN, Darex Specialty Polymers has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processe s. Refresher training is provided at least every 5 years and more frequently as needed. Mechanical Integrity W. R. Grace & Co -- CONN, Darex Specialty Polymers carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. The most recent review/revision of maintenance procedures was performed on 02/01/1999. Management of Change Written procedures are in place at W. R. Grace & Co -- CONN, Darex Specialty Polymers to manage changes in process chemicals, technology, equipme nt and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at W. R. Grace & Co -- CONN, Darex Specialty Polymers. The most recent review was performed on 05/20/99. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits W. R. Grace & Co -- CONN, Darex Specialty Polymers conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 03/15/1998. These audits are carried out at least every 3 years and any corrective ac tions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation W. R. Grace & Co -- CONN, Darex Specialty Polymers promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation W. R. Grace & Co -- CONN, Darex Specialty Polymers truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in par ticular. Contractors On occasion, our company hires contractors to conduct specialized maintenance, construction and various other activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. W. R. Grace & Co -- CONN, Darex Specialty Polymers has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also required to inform W. R. Grace & Co -- CONN, Darex Specialty Polymers of any hazards they may introduce at the site. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History W. R. Grace & Co -- CONN, Darex Specialty Polymers has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, only one accidental release has occurred during this period. There has been only one accidental release as defined by the RMP rule of regulated substances from our facility within the last 5 years. This release took place on 03/21/1996 and involved 0.025 lb. of Toluene diisocyanate. No deaths or injuries occurred offsite as a result of this accident. Onsite, there was one injury. 6. Emergency Response Plan W. R. Grace & Co -- CONN, Darex Specialty Polymers carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Owensboro Daviess County is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. A 1,3-butadiene risk reduction project, installing safety critical toxic and explosive vapor detection meters with alarming systems, removing fragile equipment from safety critical service, and installing emergency block valves are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by 5/31/2000. Name: Eric Squire Signature:____________________ Title: Responsible Care Coordinator and Manufacturing Site Leader Date Signed: ____________ |