GE Plastics - Mt. Vernon - Executive Summary |
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EXECUTIVE SUMMARY 0.1 INTRODUCTION GE Plastics has a long-standing history of commitment and performance of safe operations, while providing economic stability to the region as Posey County's largest employer. To that end, we have developed an extensive program to ensure the safety of our employees and the surrounding community. We operate under Process Safety Management guidelines, a rigorous set of standards that govern our daily control methods and behaviors. These guidelines have been adopted to satisfy the stated policy of GE Plastics to safely manage our site operations. But more than just policy drives us to put safety ahead of all other factors, including financial issues. We pledge to take care of the people who work here and the community around us because they include our family, friends and neighbors. In short, this region is our home. We recognize that to do otherwise would weaken the economic foundation on which our community is built. The Mt. Vernon site has been the b ackbone of the global GE Plastics business for nearly 40 years and the people working on the site are committed to building upon that positive legacy for decades to come. The Risk Management Plan contained in this report is a continuation of that effort, ensuring that there is a solid integration of our site emergency response resources with those available in the community, and that effective communication channels are in place. Our intensive series of internal reviews and the Occupational Safety and Health Administration's (OSHA) external audit process have validated the strengths of the programs we have in place. We have been recognized by OSHA, under the Voluntary Protection Program (VPP), as being among the best in the nation for worker safety. We have been designated a STAR site, the highest recognition OSHA gives. We believe it is important for all interested parties to have access to information that can help them better understand our business and our facility. If you have a ny questions about this document, or any other aspect of our company, please contact our Community Relations Representative at (812) 831-7621. 0.2 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES GE Plastics is committed to operating safe and environmentally sound chemical and plastics production facilities. Protection of our neighbors and workers is the highest priority everywhere we do business. This ongoing commitment to worker and public safety is demonstrated through resources invested for safe design, operation, and maintenance of our facilities. To provide top quality products for our customers, the manufacturing process at the GE Plastics-Mt. Vernon facility uses some raw materials that are classified as toxic or flammable. While we are committed to 100 percent compliance with governing laws, regulations, and engineering standards, as well as systematic assessments used to manage and maintain safe operations with these materials, we routinely go far beyond the regulatory requirements. Our operating practices and procedures, along with our automated control systems, ensure all steps are taken to prevent an accidental release of a chemical. In the unlikely event of a major release, our trained on-site emergency response organization would be activated. This organization includes a fire brigade, medical and chemical emergency response teams staffed with GE personnel who have collectively committed thousands of hours to training. Many of these individuals are so committed to emergency response, they serve on their community fire and emergency response departments as well. As a result, they devote much of their personal time to additional drills, training and community response. Effective maintenance and implementation of such a contingency plan relies on strong cooperation with the community's emergency response teams. We consistently network with other emergency response providers in our county, as well as those in neighboring counties. We ar e members of the Chemical Leadership and Education Awareness Resource (CLEAR), a group of businesses, local government agencies, and community organizations interested or involved with chemical use in Posey County. In addition, GE employees are active members of the Local Emergency Planning Committee, the Advisory Liaison Emergency Readiness Team (ALERT) Committee and the Disaster Recovery Business Alliance of Southwestern Indiana. These alliances ensure that we'll be able to quickly activate and depend on internal, as well as external, emergency response resources should the need ever arise. 0.3 DESCRIPTION OF THE FACILITY AND REGULATED SUBSTANCES The GE Plastics-Mt. Vernon plant is the largest fully integrated polycarbonate facility in the world, sitting on a 1000+ -acre tract along the Ohio River, about two miles south of the city of Mt. Vernon, Indiana. It was built in 1960 and currently employs about 1,650 people in the Southern Indiana area. GE Plastics manufactures engineered plastics, marketed under trade names such as LEXANR, ULTEMR, VALOXR, and others. Our products are used in a vast array of applications, including the automotive, medical, electronic, construction, computer, and appliance industries. Unlike most plastics manufacturing locations, the Mt. Vernon site houses four separate businesses, plus support services and research. It's headquarters to three of the GE Plastics-Americas businesses, as well as the Structured Products manufacturing plant and the Mt. Vernon Technology Department, where more than 80 top scientists and engineers work on the cutting edge of plastics innovation, developing materials and applications for new products and plastics manufacturing processes. Both work-place safety and environmental protection are part of the culture at the GE Plastics facility, with more than $500 million being invested in the site since 1991 for expansion, capital improvement, safety and environmental protection. These improvements have lead to recognition by the states of Indiana and Kentucky. Most recently, in 1998 the Chlorine Institute recognized the Brine Recovery Unit for having the largest continuous reduction in OSHA recordable injuries over the previous three-year period. The Mt. Vernon plant uses five chemicals that are regulated under the EPA's Risk Management Program (RMP) rule. These are: Mono-methylamine (MMA), a regulated flammable substance; Phosgene, a regulated toxic substance; Chlorine, a regulated toxic substance; Nitric acid, a regulated toxic substance; and Ammonia, a regulated toxic substance. Phosgene, chlorine, mono-methylamine, and nitric acid are raw materials used to manufacture our products. Ammonia is used as a refrigerant in our manufacturing process. 0.4 HAZARD ASSESSMENT RESULTS As part of our risk management planning, we specifically have identified the type of event that, should it ever occur, would have the most negative impacts on our workers and our neighbors. The RMP regulation r efers to this as the Worst-Case Scenario (WCS). As defined by EPA, we are required to assume that the numerous engineering and administrative safety controls we have in place to prevent or mitigate such accidents have all failed at once. EPA defines a worst-case scenario as a catastrophic failure, which is an event that essentially results in the 10-minute release of the contents in the largest single vessel on-site that results in the greatest distance to the EPA-defined level-of-concern. Two types of consequences must be evaluated: a release of an EPA-listed toxic chemical and a release of an EPA-listed flammable chemical. In reality, even EPA admits that the likelihood of this occurring is indeed rare. Actually, EPA advises that discussing non-worst-case scenarios, such as the Alternative Release Scenarios (ARS) described below, with the community is more useful and more appropriate for the purposes of developing community emergency response plans. Nonetheless, as outlined in th e regulation, the worst-case scenario for the Mt. Vernon site would involve the catastrophic failure of a storage tank containing liquid phosgene and the simultaneous failure of the safety ventilation and control system that prevents phosgene emissions reaching the atmosphere from the building enclosure. The quantity of material released is assumed to be 21,000 pounds of phosgene. Under this scenario, the phosgene liquid is assumed to completely evaporate and the vapors disperse in the direction of the prevailing wind. According to EPA guidelines, exposure to phosgene can occur without serious health effects at levels up to 0.2 parts per million (0.00081 mg per liter) for approximately one hour. The Worst-Case Scenario (WCS) involving RMP-regulated flammable materials at the facility assumes the unlikely failure of a mono-methylamine (MMA) storage tank, which could result in the immediate release of up to 59,000 pounds of gas. The assumption is that the gas would ignite and result in a vapor cloud explosion. A scenario using more realistic assumptions involves a rupture of a pipe containing up to 3 percent phosgene gas. EPA defines this as the Alternative Release Scenario (ARS), typically used for emergency planning purposes. This assumes as much as 16 pounds phosgene would be released within a 10-minute period. We already have in place perimeter gas analyzers that would detect such a line rupture and allow operators to shut down and isolate the pipe within 10 minutes, enabling us to mitigate the impact of this scenario. The ARS for chlorine involves an upset in our chlorine manufacturing process releasing 17 pounds of chlorine gas. The ARS for nitric acid involves a leak in a pipe connection to the nitric acid storage tank releasing 198 pounds of nitric acid. The ARS for ammonia involves a leak in a pipe connection to the ammonia storage tank releasing 785 pounds of ammonia during a 10-minute duration. The ARS for mono-methylamine (MMA) involves failure of a piping gasket connection on the storage tank over a period of two hours. This could result in a release of up to 308 pounds of MMA vapor during a two-hour period. Close and routine monitoring by trained and certified operators and the existence of remote shutoff valves and on-site fire brigade and chemical response teams would mitigate the impact of this scenario. 0.5 GENERAL ACCIDENTAL RELEASE PREVENTION / CHEMICAL-SPECIFIC PREVENTION STEPS GE Plastics complies with a comprehensive program to prevent accidental releases of highly hazardous chemicals known as Process Safety Management (or PSM). The programs ensure that proper safety information is in place; operating procedures are followed; chemical hazards are identified; employees and contractors are trained; and critical equipment is properly inspected and maintained. The programs satisfy the accidental release prevention requirements of the RMP. Some of the many, specific safety features in place to prevent a chemical accid ent include: REGULATORY COMPLIANCE 7 Safety procedures that reduce the potential for human error, which could lead to a storage tank overfill; 7 Secondary containment dikes around storage tanks to contain a spill; 7 Routine pipe and vessel inspection and testing; 7 Written operating procedures that include emergency response actions; 7 Comprehensive employee and contractor training programs to promote consistent safe work-practices; 7 Maintenance programs to ensure ongoing equipment reliability - including equipment testing and inspection; 7 A safety procedure to review proposed plant modifications before they are implemented for possible hazards - this is called "Management of Change"; 7 Safety pre-qualification for all contractors; 7 Safety reviews prior to startup of our processes; and, 7 Safety permitting procedures that control hazards during special operations such as welding and other maintenance activities. VOLUNTARY RISK REDUCTION 7 Computer-controlled safety systems on the phosgene tanks and piping to ensure that any deviations from the intended operating conditions are immediately identified and corrected; 7 Chlorine, phosgene, nitric acid gas and ammonia gas sensors to detect and warn of a release; 7 State-of-the-art safety building enclosures around nitric acid, phosgene and chlorine equipment to contain emergency releases; 7 Dedicated emergency safety equipment that cleans or "scrubs" chlorine or phosgene gas in the event of an emergency release from the manufacturing process; 7 Separate, dedicated control equipment that cleans or "scrubs" chlorine or phosgene gas from process vent systems; 7 Transfer of chlorine and phosgene liquid is done within a double-walled or "pipe-within-a-pipe" system to prevent leaks to the atmosphere; EMPLOYEE EDUCATION AND TRAINING 7 Extensive safety information about the processes reviewed with employees and contractors; 7 Comprehensive employee and contractor training programs to promote consistently safe work-practi ces; 7 Zero tolerance for exposure to chlorine, phosgene or other chemicals of concern 7 Training in Six Sigma quality processes; 7 Stable operations, which requires consistent operations within a data-supported optimum performance zone; 7 Applied PSM elements and processes to non-regulated processes 7 Constant effort in emissions reduction, including improved processes to reduce fugitive emissions. GE Plastics is engaged in an aggressive and comprehensive effort to identify and address Year 2000 issues. We are in the process of inventorying our equipment at the site, interviewing suppliers, putting into place corrective actions where necessary, and developing a contingency plan. We are on track to complete this process prior to critical roll-over dates and believe we have addressed the systems and equipment necessary for safe site operation. 0.6 FIVE-YEAR ACCIDENT HISTORY The Mt. Vernon site has an outstanding record of accident prevention that demonstrates the commitment to empl oyee and public safety. Even minor incidents are investigated to identify what went wrong and to learn how to prevent future occurrences. In keeping with the requirement to report all incidents in the past five years that involved regulated chemicals and resulted in an off-site impact or had a significant on-site impact in this document, only one incident applies. On Oct. 13, 1994, a release of chlorine vapor totaling 34 pounds occurred due to a rupture of a demister tank (17 pounds) and separate back pressure of the chlorine cells (17 pounds) during start-up of our chlorine manufacturing process. There was no off-site impact and no one was injured. There was on-site property damage, but all safety systems functioned as designed to prevent further release of materials. Following this incident, GE increased the level of safety control automation and implemented revised start-up procedures to prevent future occurrences. 0.7 EMERGENCY RESPONSE PROGRAM The Mt. Vernon site maintain s a written emergency response program designed to protect workers, the public, and the environment from all levels of accidental release. Our trained fire brigade, medical and chemical response teams participate in a mutual aid agreement with emergency response providers within our own and surrounding counties and are active members of the Local Emergency Planning Committee and the Disaster Recovery Business Alliance. These affiliations enable us to maintain close working relationships with area hospitals, industries, and other response organizations in the Southern Indiana area. We've also invested in the equipment needed to respond to emergencies, both on-site and off-site, and staff a 24-hour, seven-day-a-week command center program. We consistently review existing systems and procedures to guarantee the best and most timely emergency response possible. For example, within the last 18 months, emergency drills, organized and directed by the GE emergency teams have included: 7 A si mulated barge incident conducted with local industrial participants and Coast Guard officials; 7 A simulated chemical tanker truck leak; 7 A simulated chemical tank leak; 7 A simulated rail-car leak; 7 Provided technical assistance to CSX railroad during an actual railroad incident; 7 Annual site wide fire and toxic material drills for all personnel; 7 Several drills with the Mutual Aid participants and the fire response groups; and 7 A weekly test of the GE plant-site emergency alarm system. Ongoing training exercises are important to the company's emergency response organization and help better prepare our partners in the community for emergency response necessary in the unlikely event of a major industrial incident. In March 1985, in partnership with local industry and response organizations, GE Plastics introduced Advisory Liaison Emergency Readiness Team group (ALERT) siren system in the city of Mt. Vernon and the surrounding area. The five-siren system can be heard within 4 + miles from the center of town. Though we have never had to activate the sirens on an emergency basis because of an event at GE Plastics, the siren system is available to warn the public in the unlikely event of a major incident. The system has been designed to enhance the area's emergency response services and has been used multiple times for severe weather emergencies. Information on how residents can shelter and properly respond in the event of a chemical emergency is available from the city of Mt. Vernon, the ALERT group or in the local telephone book. GE personnel have helped develop emergency preparedness plans for the local community. In addition, they are members of the Posey County Local Emergency Planning Committee (LEPC) , are active members of the Mt. Vernon mutual aid association, as well as belonging to many local emergency response teams. The site emergency response leader and fire chief has more than 20 years of experience participating in and coordinating emergenc y response initiatives for the Posey and Vanderburgh county communities. 0.8 PLANNED CHANGES TO IMPROVE SAFETY GE Plastics is committed to continuously improving the overall safety and environmental performance record at the Mt. Vernon facility. Already identified in the ongoing effort to improving safety and emergency response are: Continuing development of best management practices under OSHA's Voluntary Protection Program (VPP); 7 Implementing behavioral training programs for employees to further reduce the chance of human error leading to a workplace injury or an accidental release; and, 7 Continuing development of technologies to keep the needed inventories of impacted chemicals at the minimum. |