Rohm and Haas, Inc. - Executive Summary

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Rohm and Haas Company - Croydon Plant 
Risk Management Plan 
Executive Summary 
1.0 Introduction 
The Rohm and Haas Company Croydon Plant is committed to operating and maintaining processes safely and responsibly.  Our continuing work to prevent accidents and releases from occurring, as well as our preparations to respond to incidents should occur, help to ensure the safety of our employees and the public as well as protection of the environment.  This summary provides an overview of the risk management activities at the Croydon Plant, and a discussion of our response to the EPAs Risk Management Program.  This summary includes: 
  2.0 General Facility Information 
  3.0 The EPAs Risk Management Program 
  4.0 Regulated Substances 
  5.0 Accidental Release Prevention and Emergency Response Policy 
  6.0 The Rohm & Haas Croydon Plant Accident Prevention Program & Chemical Specific Prevention Steps 
  7.0 Five Year Accident History 
  8.0 Emergency Response Program  
  9.0 Worst Case and 
Alternative Case Release Scenarios 
10.0 Planned Changes to Improve Safety  
2.0 General Facility Information 
The Croydon Plant is a specialty chemical manufacturing facility located in the Bristol Township, Bucks County, Pennsylvania.  The plant was built in 1969 and is part of a larger site, the Bristol Complex originally built in 1909.  Today, the Bristol complex includes a polymers production facility, research facility, corporate engineering group, and utilities areas for generation of power and waste water treatment.  The Croydon Plant shares many of the services provided at the Bristol Complex including a unified emergency response network.  Of the total site area of 800+ acres, only 250 acres are in actual usage with the balance of the area utilized as open space accommodating a variety of plant and animal species. 
The Croydon Plant produces over 100 different products which are sold to other manufacturers who use them as key components in consumer products.  The Croydon Pla 
nt produces emulsion products which are used as  coatings and binders.  Emulsion coating products are used in interior and exterior latex paint and traffic line formulations.  In addition, these products are found in floor polishes, adhesives, inks, coatings and binders for paper products, as well as caulking, cement and concrete.  The Croydon Plant produces environmentally friendly products which contain no organic solvents. 
Croydon Plant produces more than one quarter million pounds of product annually, and employees 151 personnel.  The plant works with the Bristol Complex contributing to a variety of charitable organizations within the community and provides support to the Habitat for Humanity.   The Bristol Complex works closely with its Community Advisory Council (CAC) to identify the needs and community concerns. 
3.0 The EPAs Risk Management Program 
In a series of rules promulgated between 1994 and 1998, the U.S. Environmental Protection Agency established the Risk Management 
Program (RMP) under Clean Air containing a list of toxic and flammable chemicals.  Facilities that manage more than a threshold amount of a listed chemical are subject to the RMP.  Covered facilities must assess the risks associated with their management of the listed chemicals and produce a plan to prevent releases and accidents.  In order to assist in emergency planning, covered facilities must evaluate "worst case" and "alternate case" scenarios that would result from the release of a listed chemical.  Finally, the covered facility must make their risk management program available to the public.  This document is part of Rohm and Haas Croydon Plants RMP communication effort.   
4.0 Regulated Substances 
The Croydon Plant uses three RMP toxic chemicals:  
  *Acrylonitrile monomer, Vinyl Acetate, Aqueous Ammonia (29.4%) 
5.0 Ac 
cidental Release Prevention and Emergency Response Policy        
Rohm and Haas Croydon Plant has a long standing commitment to provide a safe workplace and to prevent accidental releases.  This commitment is set forth in Rohm and Haas environmental, health and safety policies: 
** We will ensure our worldwide operations and products are free from significant risks to the health and safety of our employees, customers, carriers, distributors, the general public, and to the environment. 
** We will meet or exceed all applicable laws and regulations, participate in voluntary initiatives such as Responsible Care. and strive for continual improvement in our Environmental, Health, and Safety performance. 
** We will provide our employees with a safe workplace and support their efforts to work safely. 
** We will strive to eliminate or reduce emissions, discharges, and wastes from every stage of our operations. 
** We will communicate, listen and be responsive to our employees, customers 
, neighbors, and governments, and we will share information concerning potential hazards resulting from our operations or our products. 
The types of risk management programs required by the RMP have long been in place at the Croydon Plant.  Safe operation is a plant and company priority, and is reflected in policies as well as everyday activities.  
6.0 The Rohm and Haas Croydon Plant Accident Prevention Program and Chemical Specific Prevention Steps   
Croydon Plant maintains a number of accident prevention programs in order to ensure safe operation of all processes.  The Croydon Plant complies with OSHAs Process Safety Management (PSM) rule, which is nearly identical to EPAs Risk Management Program (RMP) rule. Additionally, the Plant follows corporate and plant-specific safety standards, which in some cases are more stringent than the OSHA general safety standards.  The Croydon Plant also participates in OSHAs Voluntary Protection Program which focuses on continued workplace safe 
ty practices.  The following items are part of our ongoing program to prevent releases and incidents:  . 
6.1)  Employee Participation  Employees are involved in many activities to continuously improve plant safety.  Employees participate in safety committees, job safety analysis, audits, design and pre-startup safety reviews, process hazard analysis, training, procedure development and monthly safety meetings. 
6.2)Process Hazard Analysis - Various process hazard analysis techniques are used to identify and analyze the potential hazards associated with the chemicals and processes we use. Corrective action plans are developed and implemented as part of the analyses and updated a minimum of every five years.  Safety systems are designed into the processes.  These are designed to create several layers of protection, so that if one system fails other systems will maintain the process in a safe state.  Examples include: 
   * Redundant safety systems and instrumentation, particularly f 
or tank level systems 
   * Automatic shutdown devices that are triggered if critical safety equipment malfunctions 
   * Secondary containment for storage tanks 
   * Alarm systems and automatic shutdown devices for critical control parameters 
   * Pressure relief devices to prevent over pressurization 
   * Fire protection systems 
   * Operator surveillance of unloading operations 
   * Permit system to control work in hazardous areas 
   * Work preplanning and safety reviews 
6.3) Operating Procedures  Operating procedures have been developed for all processes to insure safe operation.  Employees that operate the manufacturing process are included in the development, training and periodic review of these procedures.  Our processes are ISO  9002 certified.  
6.4) Employee Training  Training programs have been developed and implemented  to ensure that all affected employees understand the hazards of the chemicals used and the required safe handling procedures.  Employees involved 
in operating the manufacturing processes are trained, tested, and qualified.  During 1998, all key operating personnel have been tested and recertified as part of OSHA PSM. 
6.5)    Mechanical Integrity  This program was established to ensure the integrity of process equipment.  Elements of this program include: 
   * Identification and categorization of equipment and instrumentation 
   * Inspections and tests 
   * Establishment of inspection frequencies 
   * Development and application of maintenance procedures 
   * Training of maintenance personnel 
   * Documentation of tests and inspection results 
6.6) Pre-Startup Safety Reviews  Safety reviews of new processes, major projects, and new chemicals are conducted to ensure safe transition into the manufacturing process.   
6.7) Hot Work Permit  This system manages welding, cutting, brazing and other ignition sources throughout the plant to prevent fires and explosions. 
6.8) Management of Change  This procedure is in place to 
properly manage the changes involving processes, chemicals, technology, equipment or facilities.  
6.9) Contractor Training and Safety Reviews  Contractors are evaluated to ensure they have the appropriate job skills, knowledge, training and certification to perform their assigned work safely.  The primary plant contractor has an on-site safety supervisor.  The safety performance of contractors is periodically reviewed. 
6.10) Incident Investigation  Any incidents or near misses involving the release of hazardous material are investigated by a team of skilled and knowledgeable plant personnel.  These investigations identify corrective actions, evaluate our management systems and are documented and communicated throughout the company in a narrative report.  Any required corrective actions are tracked for timely completion. 
6.11) Compliance Audits  Audits of our Process Safety Management System are conducted  every three years.  These audits review accident prevention activities to  
ensure the requirements of the programs are being met.  
7.0 Five Year Accident History 
The RMP rule requires each company to include a description of all accidental releases from covered processes that result in deaths, injuries, or significant property damage on-site, or known off-site deaths, injury, evacuation, sheltering in place, property damage, or environmental damage.  The Rohm and Haas Croydon Plant has had no events meeting this criteria during the last five years. 
8.0 Emergency Response Program  
The Rohm and Haas Croydon Plant plan is incorporated into a unified emergency response plan for the Bristol Complex.  This Consolidated Emergency Response Plan is  coordinated with the Bucks and Burlington County Local Emergency Planning Committees (LEPC), Bristol Township, and Croydon Fire Company.  New employees are trained on handling emergencies prior to working in a process area and plant personnel review the plan annually.  The plant has an extensive alarm system, which inc 
ludes key alarms which sound at the Bristol Complex plant gate house.  The plant has an on-site fire brigade, mobile fire suppression vehicles, Hazmat Technicians as well as certified emergency medical personnel. The site has mobile foam capabilities to control vapor release.  All emergency response personnel receive ongoing monthly training.  The complex has 24-hour emergency response capabilities and can respond to both on-site and transportation off-site hazardous materials releases.  The complex is also part of the Rohm and Haas regional response network and provides offsite response into the community when requested on a mutual aid basis.  Complex emergency response personnel have radio communications with the Bucks County 911 center.  Emergency response personnel can be self dispatched, or dispatched through the County 911 center.  The Complex is also able to access the Community Alerting Network (CAN) through the Bristol Township Emergency Management Department.   Plant drill an 
d mutual aid response activities are practiced annually. 
9.0 Worst Case and Alternative Case Release Scenarios 
The RMP rule provides detailed requirements that define a worst case scenario (WCS), namely a release of the entire contents of the largest storage vessel  occurring  under very stable weather conditions (Stability F), at a low wind speed (1.5 m/sec) and the hottest day over the past three years (1020 F).  EPA notes that the worse-case scenario is designed principally to support a dialogue between the source and the community on release prevention, and not to serve as the sole or primary basis for emergency planning. Based on previous history, in addition to the several layers of protection in place, these worse-case scenarios are highly unlikely to actually occur. 
The RMP rule also defines the alternate release scenario (ARS).  Unlike worse-case scenarios, the ARS can be limited by active mitigation safeguards, such as alarms, automatic shutdowns, and operator intervention 
s.   According to EPA, an ARS is a more useful communication tool for the public and first responders and for emergency response preparedness and planning.   More realistic weather conditions (Stability D), wind speed (4.3 m/sec) and temperature (54.60 F) are used for this evaluation. 
Worst Case Scenarios:   
Rohm and Haas Croydon Plant has identified one WCS for a toxic material based on the RMP definition. 
Worst Case Toxic 
This scenario involves acrylonitrile, which is considered a toxic material under the RMP rule.   It assumes the loss of the entire inventory of a 130,000 railcar to an asphalt and earthenarea of 8900 sq. ft. over a ten minute period.  Loss to a larger area is prevented by the natural contour of the land, berming and dike wallsThe results show that if such a release occurred it would have an off site effect. Because of the plant controls, procedures and training, the worse case event is extremely unlikely. In addition, the construction of the railcars used to trans 
port acrylonitrile would make this scenario unlikely. 
Alternate Release Scenario 
The Croydon Plant has identified three ARS: one for each toxic material (3).  These scenarios were chosen after reviewing process hazard analysis, the plant spill history, and discussing alternatives with knowledgeable and experienced unit personnel.  The scenarios we have identified are more credible than those described in the worst case, but are still very unlikely given of the multiple levels of protection and extensive employee training.  
Alternate Release Scenario (ARS) - Acrylonitrile (Toxic Liquid) 
The RMP rule requires an alternate release scenario (ARS) be picked for each covered toxic material. The following is the alternate scenario description for failure of a acrylonitrile pump seal: 
This scenario assumes the failure of a mechanical pump seal during operation.  It is assumed that leakage would be through the equivalent of a one (1) inch hole allowing 550 pounds of material to flow into a  
concrete diked area of 77 sq. ft. Given the wind speed and weather conditions outlined previously, we would expect a plume of  711 feet from the point of origin.  The release could affect one (1) residence and two (2) businesses, depending on the direction of the wind.  The release could affect plant employees but given the prevailing wind direction towards undeveloped company owned land, this is not likely.  .  There are no environmental receptors affected. 
Alternate Release Scenario  Vinyl Acetate)  (Toxic Liquid) 
The following is the alternate release scenario description assuming that an unloading hose for vinyl acetate leaks: 
If the transfer line from a vinyl acetate railcar to the storage tank leaks, it is estimated  up to 550 pounds of vinyl acetate would be released to a concrete dike of 73 sq. ft.  The release would likely be stopped within 10 minutes because railcar unloading operations are monitored to minimize the risk of accidental release. Given the wind speed and weat 
her conditions outlined previously, we would expect a plume of  297 feet from the point of origin. No residences or environmental receptors would be affected.  .   
Alternate Release Scenario  Ammonia (concentration of 29.4%)  (Toxic Liquid) 
The following is the alternate release scenario description for overfilling an  aqueous ammonia storage tank. 
This scenario assumes  a 1000 pound spill occurring from overfilling an aqueous ammonia storage tank during loading operations.  The scenario assumes that the release would last 18.4 minutes and would be captured in a concrete dike with a 397 sq ft. area.  Given the weather and temperature conditions previously referenced, we would expect a release distance of up to 129 feet.  There are no residences or environmental receptors within this toxic endpoint circle.  This spill is unlikely to occur given Department of Transportation regulations requiring offloading personnel to be within 25 feet of the tank wagon at all times to prevent overfi 
10.0 Planned Changes to Improve Safety  
The  focus on safety is strong throughout the Rohm and Haas Company.  Rohm and Haas continuously looks for ways to reduce risks and to improve safety performance.  The Croydon Plant safety program is integrated into all parts of plant operation and involves the identification and implementation of  ways to improve safety performance.  For example, the plant has switched from TKOs to Differential Pressure Transmitters to minimize the risk of overfilling storage tanks.  The plant has also developed procedures to off load acrylonitrile railcars immediately upon arrival and to minimize other vehicular traffic in the rail yard during off loading operations. The Croydon Plant will continue to identify and implement other safety improvement opportunities as they are identified.
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