H.B. Fuller - Roseville Plant - Executive Summary |
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Executive Summary 1.0 Accidental release prevention and emergency response policies We, at the H.B. Fuller Company's Roseville plant, are committed to employee, public, and environmental safety. Our various accidental release prevention programs covering areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility demonstrate our commitment. It is our policy to implement appropriate controls to prevent possible releases of regulated substances as well as adhere to all applicable federal and state regulations. 2.0 The stationary source and the regulated substance handled The facility's primary activity involves the polymerization of Vinyl Acetate Monomer (VAM) and the formulation of several water-based adhesives. VAM is a key ingredient in the production of our adhesive and it is also a Clean Air Act Amendments (CAA) section 112(r) regulated substance. VAM is received mainly by railcar transport and som etimes by truck and stored in one storage tank. The raw material is subsequently metered through a series of pipes and pumps and is ultimately polymerized in the manufacturing process. The resulting water-based emulsions are then combined with other chemicals in vessels such as reactors and mixing tanks to produce the finished adhesive product. Access to the site is restricted to authorized facility employees, management personnel and contractors. Visitors are escorted while touring the plant. 7 The regulated substance handled at this manufacturing facility is Vinyl Acetate Monomer; 7 The maximum amount of VAM stored in a single vessel at this plant is 234,000 pounds. 3.0 The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario Worst Case Scenario In determining our worst case scenario, we used EPA's Offsite Consequence Analysis (OCA) Guidance Reference tables a nd Equations to determine both the release rate and the distance to the endpoint. The analysis assumed catastrophic failure of the VAM storage tank when filled to capacity (i.e., 30,000 gallons) resulting in a release of 234,000 pounds. The OCA Tables and Equations show that an accidental release of this magnitude would have an off-site impact. Passive mitigation measures currently installed to minimize the off-site impact include a large secondary containment area partially enclosed with a roof. A series of tall dikes and sumps limit the exposed surface area of pooled liquid in the event of an accidental spill. These passive mitigation measures reduce the release rate in the event of tank failure to 95 pounds per minute. This rate represents a continuous unabated release period of over 40 hours in order for the entire 234,000 pounds to evaporate. In our opinion, this is an unlikely event. In addition to the secondary containment already mentioned above, the VAM storage tank area also has a foam fire protection system installed in the roof above the tanks. The foam deluge system uses both ultraviolet and infrared detectors to monitor the tank storage area. The tank farm is in a concrete pit below grade level to moderate the storage temperature and minimize tank breathing losses. Alternative Case Scenario Our chosen alternative scenario assumed a mixing vessel overfilled beyond its capacity with VAM. This alternate case presupposed maximum pump discharge rate for 15 minutes without interruption. We chose this particular scenario because overfilling a mixing vessel has occurred previously. This specific example results in an estimated distance to the toxic endpoint of less than .1 miles and a release rate to the outside air of less than 1 pound per minute. The resulting exposures and impacts generated by EPA's OCA model showed minimal impact to the neighboring community. Active mitigation measures such as audible and visual high level alarms (set at different capacities) are installed in the equipment to minimize the possibility of overfilling the mixing vessels. In addition, there is a mechanical high-level shutoff switch installed inside the vessel to automatically interrupt the VAM discharge if the level reaches a predetermined capacity. 4.0 The general accidental release prevention program and chemical-specific prevention steps Our Roseville facility has taken all the necessary steps to comply with the accidental release prevention requirements described in 40 CFR part 68. Our adhesive manufacturing process utilizing VAM is subject to the OSHA Process Safety Management (PSM) standard under 29 CFR 1910.119. Our facility is also subject to EPCRA section 302 notification requirements. The following sections briefly describe the current elements of the release prevention program in effect for the VAM polymerization process. Process safety information Our facility maintains records on safety information that describes the che mical hazards, operating parameters, and equipment designs associated with all covered processes. Process hazards analysis Our facility conducts safety studies to ensure that hazards associated with our processes are identified and controlled efficiently. The technique used to carry out these analyses is the "What-if" methodology. The studies are undertaken by a team of facility personnel with expertise in engineering and process operations and are revalidated whenever necessary. All findings related to the hazard analysis are addressed in a timely manner. Operating procedures For the purposes of safely conducting activities within our covered process, the Roseville plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, sequence of raw material additions, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularl y reviewed and readily accessible to operators involved in the process. Training The plant has a training program in place to ensure that employees are competent in operating procedures associated with the VAM utilizing process. Refresher training or operational evaluations are provided at least every year and more frequently as needed. Mechanical Integrity The facility carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks include pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Qualified personnel carry out maintenance operations. These employees 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 the Roseville plant to manage changes in process chemicals, technology, equi pment, and procedures. Process operators, maintenance personnel, or any other employee whose job tasks are affected by a modification in process conditions are promptly informed and retrained if necessary. Pre-startup reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted at the Roseville plant. 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 The company conducts audits on a regular basis to determine whether the provisions set out under the RMP and PSM rules are being implemented. These audits are carried out at least every 3 years and any corrective actions required are undertaken in a safe and prompt manner. Incident investigation The Roseville plant promptly investigates any incident that has resulted in a reportable release of VAM. These investigations are under taken 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 The plant believes that process safety management and accident prevention is a team effort. Employees are encouraged to express their views during monthly safety meetings 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 OSHA Hazard Communications, PSM, and RMP rules, including information resulting from the process hazards analysis. Contractors On occasion, the plant hires contractors to conduct specialized maintenance and construction activities. The Roseville plant maintains a policy of informing the contractors of known potential hazards related to the contractors work and operation within our facility. Contractors are also informed of all pr ocedures for emergency response should an accidental release of VAM occur. 5.0 Five-year accident history This facility has had an excellent record in preventing accidental releases. Due to our various release prevention programs, there has been no reportable accidental releases (as defined in 40 CFR 68.42) during the last 5 years. 6.0 The emergency response program The Roseville plant 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 available medical treatment, evacuations, and notification of local emergency response agencies. To ensure proper operations, our emergency response equipment such as the sprinkler system, fire extinguishers, and fire detection systems are regularly inspected and serviced. In addition, the plan is updated to reflect any pertinent changes occurring within our process that would require a modified emergency response. 7.0 Planned changes to improve safety The Roseville plant continues to periodically evaluate the safety effectiveness of its equipment and total process through our preventive maintenance program, process hazards analysis updates, and the management of change procedures. These programmatic structures, as well as suggestions generated by employee involvement teams have led to several changes improving safety overall. We plan to continue this safety enhancement process and implement appropriate improvements whenever possible. |