Saiden Technologies - Executive Summary |
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Executive Summary Saiden Technologies, Saiden Sanford, North Carolina Plant 4/6/01 Overview of activities and facility design. Saiden Technologies is a new state-of-the-art polymerization plant built in Sanford, NC. The plant has been designed and built to best engineering practices and in accordance with all relevant codes and regulations. The plant was designed for optimal safety and efficiency by professional engineering contractors and consultants who made use of knowledge and experience garnered from over fifty years of operations at five Saiden facilities in Japan and two in Canada. Saiden Technologies uses a batch process in which monomers are reacted to form water-based emulsion polymers, which are then compounded into adhesives and other products for use in the carton, bag, label, construction, and other industries. During the polymerization process, trained operators monitor reactions frequently and document readings. Using human logic, pre-engineered safeguards, and automatic safety controls, thoroughly trained operators maintain control of the processes and prevent releases of chemicals from explosion, over-pressure or over-filling. Vinyl Acetate monomer will be stored in two bulk tanks. These tanks have been built to ANSI codes and tested before and after installation to ensure integrity. Daily operational procedures specify the use of checklists that include steps to record the tank levels and temperatures, as well as to visually inspect the dyke around the tanks to ensure no tank is leaking. The recording of the tank levels daily provides a running record that can be used with inventory records to ensure that any leaks are detected immediately. Safety Program Saiden Technologies has a strong OSHA Process Safety Management program that is designed to prevent any accidental release of highly hazardous chemicals. Upper management and company ownership have supported the development of this program and given guidance where necessary to ensure this program is enacted to its full capabilities. Early in the development of the facility, an initial Process Hazard Analysis (PHA) was conducted. While the plant was still in the "green field" stage, recommended changes to engineering plans were made before construction began. After the design was finalized, follow up PHA meetings were conducted to ensure that (1) recommendations from the initial meeting were resolved appropriately and (2) the PHA is consistent with the actual installation of the process equipment. The company found the PHA to be an outstanding tool for training employees about the process and identifying and addressing potential hazards. Not only did the PHA team address design issues, but also many necessary operating procedures, maintenance issues, and general safety issues were addressed and noted as required. All employees are encouraged to report anything they feel may cause an accident of any kind, whether it is an unsafe work practice or an unsafe cond ition. These near miss reports, as well as incident reports, will be formally investigated following the facility's incident investigation procedure. In addition, employees are encouraged to recommend process improvements, including changes in SOP's and suggestions to improve the process itself. All employee suggestions will be researched and addressed. Ownership of the safety program is very important. While developing this plan, employees have been consulted and involved at every step. The Safety Committee at Saiden Technologies encompasses all groups of employees, not just upper management or shift supervisors. Response plans Saiden Technologies emergency response plan is written to cover spills, fires and accidents. Our standard procedure will be to only fight small fires, which can be contained and put out with a hand held fire extinguisher. The local fire department will be called on to fight any large fire. The sprinkler system in the facility will be activated automat ically if heat or smoke is detected. This system is connected to a monitored alarm system, which will alert the monitoring company to call 911. The local fire department will be given a list of all chemicals and their storage locations, along with a tour of the facility. The standard NFPA labels will be on all large tanks or storage buildings for easy identification. The local fire department is to be informed of any changes in chemicals or chemical inventories. All production personnel are trained to the 24-hour HAZWOPER level to ensure that any accidental spill will be handled immediately and safely. Spill kits are located throughout the facility in the most likely areas they will be needed. Small spills will be contained, cleaned up and disposed of according to all state and federal regulations. An outside contractor will clean up any spill that is too large for Saiden Technologies personnel to handle. Saiden Technologies will do everything possible to contain the spill unt il the contractor arrives. If the spill is above the reportable quantity, the Lee County Emergency Management office will be notified of how the spill is being handled. If the release affects the natural environment or the public, the LCEM will be notified immediately so that appropriate steps may be taken. Lee County Emergency Management has been given a copy of our off site consequence analysis report and a list of chemicals with storage locations. LCEM also conducted a spill evaluation survey of the facility to verify that they have the proper information. A representative of Saiden Technologies will serve as a member of the Local Emergency Planning Committee and attend regular meetings. Among other benefits, this will enable Saiden Technologies to benchmark their safety program against the safety programs of other facilities in the Lee County area. Various types of drills will be conducted, including but not limited to tabletop, walk through, functional, evacuation, ful l-scale exercises and outside source involvement. It is important to be prepared, and during the course of a year there will be at least one full-scale exercise with smaller drills interspersed throughout the year. All drills will be evaluated for effectiveness and efficiency. Offsite Consequence Analysis Saiden Technologies has conducted offsite consequence analyses to determine how the public and the environment could be impacted in the unlikely event of an accidental release of vinyl acetate. As required by the rule, we have identified the highly unlikely worst-case scenario, as well as an alternative release scenario, for vinyl acetate. Under the worst-case scenario, we are required to identify the vessel or pipeline that holds the largest quantity of the regulated chemical, and to assume that this vessel or pipe fails, releasing its entire contents within a 10-minute period. Absolutely no consideration can be given to the many safety control mechanisms that are in place to p rotect against such an accident. We are also asked to determine the distance to the toxic endpoint of such a release. The toxic endpoint is the concentration at which nearly all people can be exposed to the chemical for up to an hour without experiencing serious health effects. Although the likelihood of such a release occurring is highly remote, EPA has required analysis of the worst-case scenario to help support a dialogue between the facility and the community on release prevention. The alternative release scenario, although still highly unlikely, is considered by EPA to be more realistic than the worst-case scenario. In this scenario, EPA allows us to take into consideration the many active and passive mitigation measures in use at our facility, because, EPA states, "...the assumption that both passive and active mitigation measures fail when such measures are specifically designed and installed to mitigate catastrophic releases is unrealistic." The following summarizes Saiden Technologies' offsite consequence analyses: Worst-case release scenario Our worst-case release scenario would be the complete failure of a vinyl acetate monomer storage tank, holding 100,000 pounds of vinyl acetate. As required by the rule, we assumed that the entire contents of the storage tank would be released within 10 minutes under worst-case weather conditions. Given this scenario, the resulting release may reach offsite receptors. In the worse case scenario we assumed a total loss of a vinyl acetate monomer tank. This will be highly unlikely due to many factors. The tanks are located in the back of the plant site protected by a concrete dyke, making the likelihood of damage from a truck or forklift high unlikely. Each tank is insulated and has a relief vent for pressure release. The relief vents have bird/insect screens to prevent clogging from an animal nest. The tanks and relief vents will be included in routine maintenance for the facility. Also, there are daily in spections of the tank levels and temperatures, and a visual inspection of the dyke. By daily monitoring any possible leak or problem will be noted and addressed promptly. Alternative release scenario Saiden Technologies considered many possibilities for the alternative release scenario. Using the PHA information and brainstorming we found that the most likely release source would be from the rupture of an unloading hose between the tank truck and the unloading pump. The rupture of the hose from the tank truck leads to a release of liquid vinyl acetate monomer that may reach offsite receptors. Saiden Technologies will have tank truck unloading procedures which include the inspection of hoses and gaskets before the unloading process begins. Also, after the employee has completed the checklist a second qualified employee must verify the integrity of all connections and ensure that the checklist is complete. During the unloading process, storm drains will be covered to prevent an a ccidental release from flowing into the storm water system. Only trained personnel will unload monomer tank trucks and verify unloading checklists. Five Year Accident History Since Saiden Technologies is a new facility, there is no 5-year accident history. Saiden Technologies has been operating an adhesive compounding facility at another location in North Carolina for over 5 years, and has not had a reportable accident or incident. (That location is neither a RMP nor PSM facility; however we have adhered to general OSHA safety regulations which have allowed us to operate effectively and safely.) Future Goals It is Saiden Technologies' intent to treat the RMP plan and OSHA PSM program as living, growing documents. As the plant operates and grows we will strive to ensure all changes are made in a manner that maintains or improves safety and environmental responsibility. We will continue to build a strong environmental, health, and safety program through employee participation, co mpliance audits, maintaining SOP's, and community involvement. |