PMD Group, Inc - Executive Summary |
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RISK MANAGEMENT PLAN EXECUTIVE SUMMARY (CFR 40 Part 68) The BFGoodrich Company Performance Materials Avon Lake, Ohio Executive Summary I.Health, Safety and Environmental Policies The BFGoodrich Performance Materials Avon Lake Plant is governed by a commitment to excellence as it pertains to Health, Safety and Environmental performance. This is exemplified by the following which are excerpts from the Plant and BFGoodrich Performance Materials Policies. ".Our mission is to accomplish business results while never compromising our ethical integri ty, community trust, and relentless pursuit of Safety, Health and Environmental excellence." "It is the policy of BFGoodrich Performance Materials to conduct our worldwide operations and business activities in a manner which is protective of our employees, our communities and the environment. Further, it is the policy of BFGoodrich Performance Materials that all business activities conform to the requirements of all applicable laws and regulations. BFGoodrich Performance Materials is committed to continuous improvement of Health, Safety and Environmental performance, the implementation of the CMA Responsible CARE program and the BFGoodrich Company Health, Safety and Environmental Policy principles." II. Stationary Source and Regulated Substances The BFGoodrich Performance Materials Avon Lake Ohio Plant is located at 550 Moore Road in Avon Lake, Ohio. At this location the toxic chemicals present th at are in excess of the applicable regulatory threshold quantity are: (1) acrylonitrile and (2) anhydrous ammonia. There are no RMP flammable chemicals present at this location in excess of the applicable regulatory threshold quantity. III. Release Scenario The worst-case and alternative release scenarios, including a discussion of administrative and mitigative measures used to minimize the affects of the release are described below. One worst case release scenario is provided for the Plant, i.e., the scenario with the farthest endpoint, and an alternative release scenario is provided for each toxic chemical. The distinguishing differences between the two types of scenarios are: (1) the USEPA specifically defines the parameters of the worst case releases scenario and (2) only the alternative release scenario takes into account the accident/release prevention measures that are in-place to prevent and mitigate any release. A. Worst Case Release Scenario The USEPA d efined worst case scenario for the Plant, involves a complete failure of the acrylonitrile storage tank during which the maximum contents (24,000 gallons) are released within 10 minutes. This scenario does not take into consideration any of the multi-layered prevention measures that are in-place to prevent this release scenario from occurring. The distance to the release endpoint as defined by USEPA, i.e., distance after which the released plume has dispersed to an acceptable concentration of 0.076 milligrams of acrylonitrile per liter of air, is 2.2 miles. B. Alternative Release Scenarios The alternative release scenarios were developed and selected in accordance with a risk based protocol. This protocol uses the process HAZOPS and integrates the likelihood of occurrence and the offsite severity potential into the scenario selection process. The alternative release scenarios and their corresponding release endpoints are: = A two minute release from the acrylonitrile tank due to overfilling. This scenario assumes that all or some of the following accident/release prevention measures fail: - The administrative inventory control system fails and an acrylonitrile shipment is received for unloading prior to having sufficient freeboard to unload the delivery. - The tank level devices fail to detect the correct level in the tank thus there is insufficient freeboard in the tank to accept a delivery. - The redundant high level tank alarms fail to automatically stop the loading pumps when a high level condition is reached. - The loading attendant does not stop loading the tank for two minutes after the overfilling is initiated. The release endpoint for the acrylonitrile alternati ve release scenario is 0.13 miles. = A sixty minute release from a pipe leak in the ammonia supply line. This scenario assumes that all or some of the following accident/release prevention measures fail: - The excess flow valve does not function. - The mechanical integrity program fails to prevent and detect corrosion leading to the leak. - The time required to respond to the release is sixty minutes. The release endpoint for the anhydrous ammonia alternative release scenario is 0.13 miles. IV. Accident and Release Prevention Programs The BFGoodrich Performance Materials Avon Lake Plant has several programs in place, which are specifically focused on preventing the accidental release of chemicals. These programs are consistent with Plant and BFGoodrich policies and with the Occupational Safety and Health Process Safe ty Management Standard (PSM) for highly hazardous chemicals. These programs are: 1. Employee Participation - Employees regularly participate in activities directed toward aspects of Plant Safety, e.g., Process Hazard Analysis, Management of Change Procedures, and monthly safety meetings. 2.Process Hazard Analysis (PHA) - Various Process Hazard Analysis Techniques are performed to identify and analyze the potential process hazards associated with handling hazardous chemicals. Corrective Action plans are then formed and implemented. 3. Operating Procedures - Operating procedures have been developed for all processes to insure the their safe operation. These procedures are periodically reviewed and modified as necessary. 4. Employee Training - Training programs have been developed and implemented to insure all employees fully understand the hazards of the chemicals in use and the required safe handling procedures. The Plant has established an Operation Certification program to train, test and certify the employees who are operating chemical processes. 5. Contractors are evaluated to insure that they have the appropriate job skills, knowledge, training and certifications to perform tasks safety. 6. For New Processes - Pre-Startup Safety Reviews are conducted to insure a safe transition into the normal operating mode. 7. A Mechanical Integrity program is in place to insure the integrity of process equipment. Elements include the following: - identification and categorization of equipment and instrumentation - inspections and tests - establishment of prescribed inspection frequencies - development and application of maintenance procedures - training of maintenance personnel - documentation of test and inspection results - documentation of manufacturer's maintenance recommendations 8. A "Hot Work" Permit System is in place to manage welding, cutting or brazing of equipment in process areas to prevent fire or explosions. 9. A Management of Change System has been implemented to properly manage changes involving processes, chemicals, technology, equipment or facilities. 10. In the event of any Chemical Release or "Near Miss" an Incident Investigation or Board of Review is conducted by a team of experienced individuals familiar with the process. All recommendations are documented and tracked through completion. 11. A highly trained, on shift, Emergency Response Team is prepared to respond to chemical release events. 12. Compliance Audits are performed to review all relevant documentation, verify process safety information and inspect the physical facilities. V. Five Year Accident History Accidents Involving RMP Chemicals During the past five years, the BFGoodrich Avon Lake Plant has had no chemical releases/accidents involving anhydrous ammonia or acrylonitrile which resulted in deaths, injuries or significant property damage on-site or known off-site deaths, injuries, evacuations, sheltering in place, property damage or environmental damage. VI. Emergency Response Programs The BFGoodrich Performance Materials has the following policies/procedures/plans in effect for use in mounting a response to the release of chemicals: - Fire and Other Emergencies - Government Reportable Releases Emergency Notification - Internal BFG Management Notification of Emergency Events - Integrated Contingency Plan - Spill Pre vention Control and Countenance Plan (SPCC) - RCRA Contingency Plan The Plant has a comprehensive notification system in place to initiate response to any emergency. Key personnel are notified by a system of pagers and alarms. Once this notification system is activated, a series of emergency plans follow. For example, in the event of a fire, the Emergency Response Team will respond and an on-site Chain of Command communication system is implemented. The Emergency Response Team is trained to deal with chemical releases and emergencies. Coordinated drills with the Avon Lake Fire Department and the Lorain County Emergency Planning Committee are conducted to insure good communication and operational effectiveness. These groups are also trained and available to assist with emergency situations. VII. Planned Safety Improvements The BFGoodrich Performance Materials Avon Lake Plant continues to evaluate and identify process hazards. As hazards are identified, corrective ac tion plans are developed and implemented. VI. Certification The undersigned hereby certifies that to the best to his knowledge, information and belief formed after reasonable inquiry, the information submitted is true, accurate and complete. Vincent A. Valentino Plant Manager |