GE Specialty Chemicals Inc. Morgantown South Plant - Executive Summary
EXECUTIVE SUMMARY |
This Risk Management Plan is part of GE Specialty Chemicals continuing commitment to minimize the potential impact from our facility on our workers, our community neighbors, or the environment. It is the stated policy of GE Specialty Chemicals to safely manage our site operations. In addition, we have prepared contingency plans to be used in the unlikely event that a major accident should occur. The efforts at our Morgantown, W.Va. facility have been recognized by the US Occupational Safety and Health Administration (OSHA), who oversees our programs, as among the best in the nation for worker safety.
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 any questions about this document, or any other aspect of our company or our plans, please contact our Community Relations Representative at (304) 284-2202.
0.2 ACCIDENTAL RELEASE PREVEN
TION AND EMERGENCY RESPONSE POLICIES
Our company is committed to operating safe and environmentally sound chemical production facilities everywhere we do business. Protection of our neighbors and workers is the highest priority. This ongoing commitment to worker and public safety is demonstrated through resources invested for safe design, operation, and maintenance of our facilities.
In order to provide top quality products for our customers, the GE Specialty Chemicals Morgantown W. Va. facility uses in its manufacturing process some raw materials that are classified as toxic or flammable. We are committed to comply with governing laws, regulations, and engineering standards as well as systematic assessments to manage and maintain a safe operation. Our operating practices and procedures ensure that numerous controls are implemented to prevent an accidental release of a chemical. However, if a major release does occur, our trained on-site emergency response organization will be ac
tivated. This organization includes medical and chemical emergency response teams.
The outstanding programs at the Morgantown facility have earned the OSHA STAR award, presented by the Occupational Safety and Health Administration for exemplary safety management. This is OSHA's highest award for safety performance.
0.3 DESCRIPTION OF THE FACILITY AND REGULATED SUBSTANCES
GE Specialty Chemicals operates two facilities, both located in the Morgantown Industrial Park in Morgantown (Westover), W.Va. These are known as the "north plant" and the "south plant". Both plants were built in 1965 and currently employ about 200 people in the Morgantown area. GE Specialty Chemicals manufactures antioxidant chemicals marketed under trade names such as ULTRANOXR, WESTONR, and others. Our products are used in various plastics, inks, coatings and adhesives for improved ultraviolet (UV), heat, color and processing stability.
The site is also home to a Technology Center, where GE conducts advanced
research in specialty chemical technology.
In order to ensure quality products, quality service and quality of life, GE has invested more than $80 million in the site since 1988 for expansion, capital improvement, safety and environmental protection.
The Morgantown W. Va. plants use one chemical that is regulated under the EPA's Risk Management Program (RMP) rule. Both the north and south plants use Phosphorus trichloride, a regulated toxic substance. Phosphorous trichloride is a raw material used to manufacture our products.
0.4 HAZARD ASSESSMENT RESULTS
As part of our risk management planning, we have specifically identified the type of event that, should it ever occur, would have the most negative impacts on our workers and our neighbors. This is known 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 instantaneous release of the contents in the largest single vessel on-site that results in the greatest distance to the EPA-defined level-of-concern.
In reality, even EPA admits that the likelihood of this occurring is indeed rare. Actually, EPA advises that discussing non-worst-case scenarios with the community is more useful and more appropriate for the purposes of developing community emergency response plans.
Nonetheless, this worst-case scenario for both the Morgantown north and south plants would involve the catastrophic failure of a commercial tank truck containing phosphorus trichloride. The quantity of material released is assumed to be 42,000 pounds of phosphorus trichloride. The secondary containment dike and enclosure around the tank truck unloading area would minimize the amount of phosphorous trichloride that could be released to the environment.
his scenario, the phosphorus trichloride liquid is assumed to evaporate and the vapors disperse in the direction of the prevailing wind. Furthermore, phosphorous trichloride is assumed to react with moisture in the air to form hydrogen chloride gas. According to EPA guidelines, exposure to hydrogen chloride can occur without serious health effects at levels up to 20 parts per million (0.030 mg per liter) for approximately one hour.
A scenario using more realistic assumptions involves the failure of a chemical hose used to transfer phosphorus trichloride from the tank truck to our storage tank. EPA defines this as the Alternative Release Scenario (ARS). As much as 42,000 pounds phosphorus trichloride could be released over a 30-minute period through the failed hose. Again, the secondary containment dike and enclosure around the tank truck unloading area would minimize the amount of phosphorous trichloride that could be released to the environment.
0.5 GENERAL ACCIDENTAL RELEASE
PREVENTION / CHEMICAL-SPECIFIC PREVENTION STEPS
GE Specialty Chemicals has implemented a comprehensive program to prevent accidental releases of highly hazardous chemicals known as Process Safety Management (or PSM). PSM is an integral part of working safely at GE Plastics facilities. PSM ensures 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. PSM satisfies the accidental release prevention requirements of the RMP.
Some of the many, specific safety features to prevent a chemical accident include:
7 Computer-controlled safety systems on the phosphorus trichloride storage and transfer systems to ensure that any deviations from the intended operating conditions are immediately identified and corrected;
7 Safety procedures that reduce the potential for human error which could lead to a storage tank overfill;
7 Secondary c
ontainment dikes around storage tanks and tank truck unloading areas to contain a spill;
7 Building enclosures around phosphorous trichloride tank-truck unloading and storage equipment to contain a leak;
7 Transfer of phosphorous trichloride liquid is done with a double-walled or "pipe-within-a-pipe" system to prevent leaks to the atmosphere - includes a leak detection system;
7 Gas sensors to detect and warn of a release of phosphorous trichloride;
7 Phosphorus trichloride unloading operations are continuously attended by US Department Of Transportation (DOT) trained operators;
7 Extensive safety information about the processes reviewed with employees;
7 Written operating procedures that include emergency response actions;
7 Comprehensive employee and contractor training programs to promote consistently safe work-practices;
7 Maintenance programs to ensure ongoing equipment reliability - includes equipment testing and inspection;
7 A safety procedure to review proposed plant modificat
ions 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-permit procedures that control hazards during special operations such as welding and other maintenance activities.
GE Specialty Chemicals 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
Over the long term, the Morgantown W. Va. site has had a positive accident prevention record that demonstrates its commitment to public and worker safety. Even minor incidents
are investigated to identify what went wrong and to learn how to prevent future occurrences.
EPA requires that all incidents involving RMP-regulated chemicals that resulted in any off-site impact or significant on-site impacts are reported in this document. During the previous five-year period, no such incidents have occurred at the plantsite involving phosphorous trichloride.
0.7 EMERGENCY RESPONSE PROGRAM
The Morgantown W. Va. site maintains a written emergency response program designed to protect workers, the public, and the environment in the event of a major accidental release. All of our employees are trained in the proper response to an incident. We also invest in the equipment needed to respond to emergencies, both on-site and off-site. Our medical and chemical response teams work closely with area hospitals, industries, and other response organizations in the Monongalia County area.
For example, recent emergency drills, organized and directed by the GE emergency
teams, have included:
7 A simulated liquid waste incident conducted in September 1996 with Monongalia County Emergency officials, and police departments from the City of Westover, West Virginia;
7 A simulated chemical tanker truck incident with Monongalia County Emergency services conducted during January 1997.
7 A simulated phosphorus trichloride incident and community-wide drill with the Westover Volunteer Fire Department, Monongalia Emergency Services and area hospitals during June 1998.
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.
Information about how to shelter yourself and your family in the event of a chemical emergency can be found in the Bell Atlantic telephone directory.
GE personnel have helped develop emergency preparedness plans for local communities. In addition, they are members
of local emergency planning and emergency preparedness groups. As consistent with the Monongalia County Emergency Response Plan, GE will work through the Monongalia County Emergency Management Commission to communicate any appropriate actions to be taken by the public in the event of a chemical emergency.
0.8 PLANNED CHANGES TO IMPROVE SAFETY
GE Specialty Chemicals is committed to continuously improving the overall safety and environmental performance record at the Morgantown W. Va. facility. Some of the specific planned changes aimed at improving safety are:
7 Continuing development of best management practices under OSHA's Voluntary Protection Program (VPP) and Process Safety Management Standard (PSM);
7 Submission for OSHA VPP renewal in 1999;
7 Implementing additional training programs for employees to further reduce the chance of human error leading to a workplace injury or an accidental release;
7 Continuing active involvement in the Local Emergency Planning Committee
and support emergency preparedness programs.