Eastman Chemical Company - Executive Summary |
|
EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the Eastman Chemical Company (Eastman) Carpentersville, Illinois facility management to implement the requirements of this RIsk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to Eastman employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. Eastman's management is committed to providing the resources necessary to implement this policy. Further, Eastman recognizes that it has a duty to protect its employee s and neighbors from the effects of all dangerous chemicals. While chemicals are a fundamental component of the coatings that Eastman manufactures, each chemical is given due consideration with regard to techniques for safe handling and processing. Therefore, even though a particular compound may not be listed within the regulations, it is handled according to any hazardous properties that it possesses. Facility Description Eastman Chemical Company is located in Carpentersville, Illinois, and operates primarily as a manufacturer of synthetic resins. The following is a description of the various resins produced on a batch basis, based on the customer demand. The main product is resin, including alkyds, aminos, polyesters, powder coating, and latex emulsions. The resins are produced via high temperature (i.e. 380-500 F) polymerization of vegetable oils, organic acids, and polyols in reactors (or kettles). The reaction products are then diluted using various solvents in mix tanks and shipped to customers in drums, 2,500-pound modular containers or by bulk in tank trucks. Products are occasionally used in-house as bases. Bases are used for production of certain modified synthetic coatings (copolymers, polyurethanes, and silicones) which are then shipped out to customers via the same three methods mentioned above. All processes are conducted in a batch mode. Support operations include a wastewater treatment system, storage tanks, an analytical/R&D laboratory, and administrative offices. One chemical, vinyl acetate, is utilized at the facility in sufficient quantities to be subject to the requirements of 40 CFR Part 68, RMP. Vinyl acetate is a raw material (monomer) used for latex emulsions. Worst-Case and Alternative-Release Scenarios RMP regulations require that each facility identify worst-case and alternative-case release scenarios. EPA has defined a worst-case release as the instantaneous release of the entire contents of the largest vessel or connected pi ping that contains a regulated substance. Certain design features, such as the buried tank used by Eastman, preclude a complete failure of the tank. As a result, USEPA guidance suggests that failure of the connecting piping be considered as constituting the worst case. The release rate is then evaluated using modeling techniques and/or reference tables to define the distance to a specified endpoint (concentration or overpressure). The distance to the endpoint is affected by several factors including molecular weight, volatility, heat of combustion, and physical setting (urban or rural). The worst-case release scenario for the vinyl acetate process included a release of 100 gallons (780 pounds) from piping that has been assumed to fail. This release translates to a release rate of 14.7 pounds per minute. Other assumptions for the worst-case vinyl acetate analysis included: the vinyl acetate is a liquid; the storage tank is located below ground (which serves as a passive mitigation t echnique); the nearfield dispersion environment is characterized as urban; 10-minute average period; the wind speed is 1.5 meters/sec, and the atmospheric stability is classified as F (stable). The results of the worst-case assessment for vinyl acetate show that the specified endpoint of 73.9 ppm is found to occur at a distance of 0.16 mile (845 ft.) from the release point. Note, however, that the dense gas characteristics of vinyl acetate will tend to minimize (or prevent) transport of the material over the surrounding terrain. The selected alternative-release scenario for the vinyl acetate process is a release that results from piping component failure (e.g., a flange leak). A dispersion model known as ALOHA was used to determine the distance to the endpoint for a spill quantity of 10 gallons (78 pounds). A spill of this magnitude was predicted to reach the endpoint after traveling a distance of 0.03 mile (156 ft.). The agency supplied default meteorological data used for this alter native release scenario was a wind speed of 3 meter/sec, an atmospheric stability classification of D, and an urban dispersion environment in the near-field. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Carpentersville facility is governed by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public and to the environment. These regulations include: >40 CFR Part 68, Accidental Release Prevention >40 CFR Part 112, Spill Prevention, Control and Countermeasure >40 CFR Part 264, Hazardous Waste Contingency Plan >29 CFR Part 119, Process Safety Management The key concepts in Eastman's release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees. Employee parti cipation in the release prevention program is encouraged and supported by Eastman management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the vinyl acetate. Eastman employees are also members of the facility emergency response team. Eastman policy is to construct all new equipment, systems, and facilities in accordance with the most current building and safety codes. This ensures the appropriate safety and release prevention systems are included from the beginning of each project. Eastman employs the following regulations design codes and standards to ensure the safety and health of its employees, neighbors and the environment.: 1. EPA 40 CFR Part 68 Chemical Accident Release Provisions (RMP). 2. EPA 40 CFR Part 112 Spill Prevention Control and Countermeasures. 3. EPA 40 CFR Part 264 and 265 Hazardous Waste Manangement. 4. OSHA 29 CFR Part 1910.119 Process Safety Management (PSM). 5. OSHA 29 CFR Part 1910.120 E mergency Response Planning. 6. National Fire Protection Association (NFPA) Standards for fire prevention and protection. 7. National Electrical Code (NEC) Standards for the design standards of electrical systems. 8. American Society of Mechanical Engineering (ASME) Standards for pressure vessel design. 9. American Petroleum Institute (API) Standards for storage tank designs. Eastman also maintains a computerized program of maintenance activities to ensure that key systems are maintained approriately to minimize the risk of a release. Eastman is committed to providing appropriate training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during his or her initial orientation for the facility. In addition, Eastman conducts regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Members of Eastman's emergency response team receive annual training to ensure that response actions are promptly and safely completed. Five Year Accident History Eastman has not had a release of vinyl acetate from the Carpentersville, Illinois facility that has caused any of the following: >On-site deaths, injuries, significant property damage, or >Off-site deaths, injuries, property damage, environmental damage, evacuations or sheltering in place. Emergency Response Program Eastman has personnel trained in emergency response at the facility 24 hours per day, seven days a week. These personnel receive annual training on emergency procedures and response techniques. Response activities are coordinated with the local fire department to ensure the appropriate level of response. Planned Changes to Improve Safety Eastman completes a thorough review of the vinyl acetate system each time a design change is implemented. Eastman is committed to using these methods to identify and implement ways to improve the safety of these sys tems. The vinyl acetate storage tank was recently replaced and a number of safety features were incorporated to minimize the likelihood of a tank failure and to mitigate the effect of any component failure. |