GE Plastics - Bay St. Louis - Executive Summary |
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EXECUTIVE SUMMARY 0.1 INTRODUCTION This Risk Management Plan is part of GE Plastics' 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 Plastics 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 Bay St. Louis, MS, 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 (228) 466-3047. 0.2 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY R ESPONSE POLICIES Our company is committed to operating safe and environmentally sound chemical and plastics 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 Plastics Bay St. Louis, MS. 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 activated. This org anization includes medical and chemical emergency response teams. The outstanding programs at the Bay St. Louis 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 The GE Plastics plant is located in the Port Bienville Industrial Park. The site is on a 530-acre tract on the northern shores of Lake Borgne, about 3 miles southeast of the town of Pearlington, Mississippi. It was built in 1981 and currently employs about 200 people. GE Plastics manufactures engineered plastics, marketed under trade names such as CYCOLACR, CYCOLOYR, and others. Our products are used in automotive, medical, electronic, computer, and appliance industries to name a few. In order to ensure quality products, quality service and quality of life, GE has invested more than $140 million in the site since 1988 for ex pansion, capital improvement, safety and environmental protection. The Bay St. Louis, MS. plant uses one chemical that is regulated under the EPA's Risk Management Program (RMP) rule. The chemical is Acrylonitrile, a regulated toxic substance. Acrylonitrile is used as a raw material 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. This worst-case scenario would involve the catastrophic failure of the largest compartment of a tanker barge containing acrylonitrile liquid. A worst-case scenario assumes a catastrophic failure is an event that essential ly results in the instantaneous release of the entire vessel contents, which is up to 901,000 pounds of acrylonitrile. Under this scenario the acrylonitrile liquid is assumed to evaporate and the vapors disperse in the direction of the prevailing wind. According to EPA guidelines, exposure to acrylonitrile can occur without serious health effects at levels up to 35 parts per million (0.076 mg per liter) for approximately one hour. A scenario used to meet the Alternative Release Scenario (ARS) requirements of the regulation involves the failure of a pipe connection to an acrylonitrile barge. As much as 12,100 pounds Acrylonitrile could be released. Since trained and certified operators continuously attend the acrylonitrile transfer operation, shutoff valves would be quickly closed to isolate this leak. 0.5 GENERAL ACCIDENTAL RELEASE PREVENTION / CHEMICAL-SPECIFIC PREVENTION STEPS GE Plastics has implemented a comprehensive program to prevent accidental releases of highly hazardou s 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 our chemical reaction vessels 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 containment dikes around storage tanks to contain a spill; 7 Spill containment around unloading stations to mitigate the impact of a leak; 7 Acrylonitrile barge unloading operations are conti nuously attended by US Department Of Transportation (DOT) trained operators; 7 Extensive safety information about the processes available to 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 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. 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, interv iewing 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 Bay St. Louis, MS. site has an outstanding record of accident prevention which 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 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 incident has occurred at the plantsite. 0.7 EMERGENCY RESPONSE PROGRAM The Bay St. Louis, MS. 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 trained emergency, medical and chemical response teams work closely with area hospitals, industries, and other response organizations in Hancock County. For example, within the last eighteen months, emergency drills, organized and directed by the GE emergency teams, have included: 7 A simulated barge incident conducted with site medical, emergency, rescue and Hazmat teams; 7 A simulated chemical tanker truck incident at GE Bay St. Louis. 7 A simulated chemical/industrial accident with Hancock Medical Center emergency room and chemical emergency response teams. 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 incid ent. GE personnel have helped develop emergency preparedness plans for Hancock County and surrounding areas. In addition, they are members of local emergency planning and emergency preparedness groups. As is consistent with the Hancock County Emergency Plan, GE will work through the Hancock County Sheriff's Department 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 Plastics is committed to continuously improving the overall safety and environmental performance record at the Bay St. Louis, MS. 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); 7 Conducting a third-party audit of our Process Safety Management system; 7 Implementing behavioral training programs for employees to reduce the chance of human error leading to a workplace injury or an accidental release; 7 An ongoing employee exposure monitoring and reduction program for Acrylonitrile; 7 Continuing monthly on-site emergency responder drills; and, 7 Continuing annual community emergency response drills |