Evans Chemetics - Executive Summary |
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Evans Chemetics Risk Management Plan Executive Summary June 1999 Accidental Release Prevention and Emergency Response Policies We at Evans Chemetics 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 highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with Seneca County LEPC which provides additional emergency response expertise. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's Risk Management Program regulation * A summary of results from our assessment of the potential off-site consequences from accidental chemical releases * An overview of our accidental release prevention programs * An overview of our emergency response program * A five-year history of accidental releases of chemicals regulated by EPA's RMP rule * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certification that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program Stationary Source and Regulated Substances Evans Chemetics was formed in Waterloo during the early 1940s to manufacture divalent sulfur compounds for the hair care and cosmetic industries. Since that time, the number of products has grown to over 50, serving the cosmetic, plastics, and specialty chemical industries. The products manufactured are sold to other manufactures as raw materials and ingredients in their final products. In our processes, Evans Chemetics uses two regulated substances, acrylonitrile [2-propenenitrile] and epichlorohydrin [oxirane, (chloromethyl)-]. Acrylonitrile is used to manufacture a variety of products, including secondary antioxidants for plastics and rubber and polymerization chain transfer agents. Epichlorohydrin is used to manufacture products used in the photographic, cosmetic, and pharmaceutical industries. Worst Case Release Scenario and Alternate Release Scenarios, Including Administrative Controls and Mitigation Measures To help understand the potential impact on the community due to a release of chemicals from Evans Chemetics, we have provided information about the worst case scenario and alternate scenarios for our facility. These scenarios were developed using the guidance and techni cal data supplied by the EPA. Scenario information similar to that described below has been used at Evans Chemetics for over ten years as part of our process safety management program. In the past we have modeled potential releases and analyzed the results to help us continuously improve our processes and reduce risk. We continue to do these assessments as part of our continuing effort to reduce any impact we may have on the surrounding community. The EPA defines the worst case scenario as a hypothetical release of the largest quantity of a regulated chemical under the worst case meteorological conditions with the complete failure of all active safety systems. This scenario assumes the entire quantity is released in ten minutes, even if it is impossible to do so. Using RMP Comp(tm), a computer program developed by the EPA and NOAA (National Oceanographic and Atmospheric Administration) to determine the offsite impact of chemical releases, the worst case scenario was determined t o be the release of the entire contents of the acrylonitrile bulk storage tank (98,500 pounds) within the prescribed ten minute period. This worst case scenario could effect the community up to 0.7 miles from the bulk storage tank. The worst case scenario described above underscores the need for the rigorous process safety management systems used at Evans Chemetics. The extensive accidental release prevention program would make the worst case scenario very unlikely. Since this worst case scenario is very improbable, they are not good cases to focus on for emergency response planning with the local community. In order to facilitate emergency response planning with the local community, EPA has included a requirement for companies to report alternate case scenarios. These alternate case scenarios provide a realistic picture of what could happen if the safety systems used by the facility were to fail. One alternate scenario for acrylonitrile and one for epichlorohydrin are describe d below. The alternate scenario for acrylonitrile is the complete failure of an unloading chemical hose while unloading acrylonitrile from a tank truck into the bulk storage tank. In this scenario, up to 1880 pounds of acrylonitrile may be spilled into a tank truck containment area. A spill of this magnitude may impact the community up to 0.2 miles from the tank truck unloading station. The alternate scenario for epichlorohydrin is a complete failure or rupture of an epichlorohydrin transfer line while pumping epichlorohydrin from the epichlorohydrin bulk storage tank to a process reactor. In this scenario, up to 1480 pounds of epichlorohydrin may be spilled onto a concrete or paved section in the facility. A spill of this magnitude may impact the community up to 0.1 miles from the location of the spill. General Accidental Release Prevention Program and the Chemical Specific Prevention Steps Evans Chemetics has taken all the necessary steps to comply with the accidental releas e 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 also subject to EPCRA Section 302 notification requirements. We have an air operating permit ID under Title V of the Clean Air Act. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Evans Chemetics maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process safety information includes Material Safety Data Sheets, equipment specification sheets and maintenance manuals, reactive chemical data, and materials of construction information. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficie ntly. The HAZOP methodology is used to carry out these analyses, along with the Dow Fire & Explosion Index and Chemical Exposure Index methodologies. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated every 3 years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures Written operating procedures are maintained on all the chemical processes operated at the facility. 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 Evans Chemetics has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed. Mechanical Integrity Evans Chemetics carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes 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. Management of Change Written procedures are in place at Evans Chemetics to manage changes in process chemicals, technology, equipment 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 o ffered 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 Evans Chemetics. 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 Evans Chemetics conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Evans Chemetics 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 corr ective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Evans Chemetics 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 particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Evans Chemetics has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are informed of all the procedures for em ergency response should an accidental release of a regulated substance occur, and are required to inform Evans Chemetics of any hazards they may introduce at the site. Five-year Accident History Evans Chemetics has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release of acrylonitrile or epichlorohydrin during this period as defined by the RMP rule of regulated substances. Emergency Response Plan All plant personnel are trained to recognize and respond to any release of chemicals. In addition, a number of people have received advanced emergency response training, and have the equipment and capability to properly respond to any chemical release. In addition to Evans Chemetics' own emergency response capability, emergency planning and response is coordinated with the Seneca County LEPC (Local Emergency Response Committee). Planned Changes to Improve Safety As pa rt of Evans Chemetics' ongoing program to improve safety within the facility and reduce risk to the surrounding community, our processes and procedures are thoroughly studied on a periodic basis to identify risk reduction opportunities. Currently we are implementing or planning to implement the following risk reduction activities: * Eliminate the storage and use of anhydrous ammonia to eliminate the risks associated with the storage, transfer, and use of anhydrous ammonia. * Install automatic block valves on the acrylonitrile bulk storage tank to isolate the transfer line when acrylonitrile is not being transferred, and to quickly isolate the transfer line during acrylonitrile transfer if necessary. * Install a foam system in the acrylonitrile bulk storage tank dike to improve fire protection and to dramatically reduce the impact of any acrylonitrile leak into the protective dike. * Replace the existing epichlorohydrin bulk storage tank with a new tank with nitrogen blanketing. * Repl ace the major epichlorohydrin transfer line identified in the alternate scenario with a smaller line, with the epichlorohydrin transfer changed from a manual batch transfer to a continuous computer monitored addition. As additional risk reduction opportunities are identified, they will be added to the above list. |