BFGoodrich Performance Materials - Gastonia Plant - Executive Summary |
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RMP EXECUTIVE SUMMARY BFGOODRICH GASTONIA, NC PLANT a. Accidental Release Prevention and Emergency Response Policies It is the policy of BFGoodrich to meet or exceed all requirements established by Federal, State and local regulatory agencies. Our safety policies and practices have historically preceded the regulation of such practices under, for example, the OSHA Process Safety Management Standard. The risk communication objective for BFGoodrich is that its operating plants will be well prepared to deal with risk communication issues in their local communities and be prepared to act decisively to minimize any impact to the community resulting from industrial activities. Each BFGoodrich plant regulated by the US EPA Risk Management Program (RMP) rule, 40 CFR 68 will complete a comprehensive RMP Plan and submit it to the appropriate state regulatory agency. This RMP Plan will include an RMP Communication Plan for the plant within its local community. The objective of the RMP Com munication Plan is that the plant will be prepared to: 7 Provide a realistic communication perspective on RMP information and on the plant's RMP submittal to EPA. 7 Explain the plant's prevention program and safeguards. 7 Provide appropriate information about the plant's emergency response procedures. 7 Explain the plant's products and positive impact on the surrounding community. Risk communication is an integral part of a comprehensive risk management program at BFGoodrich that meets or exceeds all requirements of the US EPA RMP rule as well as the OSHA rule 29 CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals (PSM). In addition, BFGoodrich is a voluntary member of the Chemical Manufacturers Association, which has undertaken efforts to improve community relations through its Responsible Care Initiative since 1988. Plant managers, HSE managers, and their designees are responsible for the timely development and submission of their plant's overall RMP program, in cluding an effective RMP Communication Plan for the plant. b. The Stationary Source and Regulated Substances Handled The BFGoodrich Performance Materials Plant in Gastonia manufactures Latex resins and coatings used in the textile, carpet, adhesives, paint, printing, coating, automotive and flock industries. The site manufactures more than 500 products sold throughout the world. The plant is located approximately three miles south of downtown Gastonia just outside the City limits. The Gastonia facility covers 23 acres, nine of which contains three separate manufacturing plants. The site was initially developed by Maurice Walsh as Walsh Chemical Company in 1973. In 1994, BFGoodrich acquired the site. The plant currently employs 125 people. The site is serviced by Norfolk-Southern Railroad, is adjacent to US Route 321, and is less than 10 miles from Interstate 85. Annual plant payroll is $5 million, paying about $180,000 in county taxes and $550,000 in state taxes. We buy $3 million in goods and services mostly from local suppliers. BFGoodrich is proud to be a part of this hard working community. The plant and its employees have generously supported the area through the annual Fish Camp Jam, United Way, Volunteer Fire organizations, The Salvation Army, The Shrine Club, Special Olympics, American Business Women's Association, Boy Scouts and Girl Scouts of America, HH Beam, Lingerfelt, Pleasant Ridge Elementary Schools, Holbrook and Southwest Middle Schools. Nearly all finished products manufactured at the Gastonia plant are non-hazardous. In the manufacture of these products, chemicals regulated by EPA's RMP rule are used. The RMP regulated chemicals for this site are acrylonitrile, 1,3-butadiene, vinyl acetate and vinylidene chloride. Even before the RMP rule was written, BFGoodrich Gastonia has had programs in place to prevent serious accidents involving chemicals. Emergency response contingency plans have been in place for more than 15 years. We have long understood the relationship between safety and good business, as reflected by our exemplary and frequently awarded safety performance record. We welcome the EPA's RMP initiative and see it as an opportunity to continue and expand dialog with our community. c. Prevention Program and Chemical Specific Prevention Steps BFGoodrich has in place a thorough, ongoing program of process safety management (PSM). This program requires implementation and maintenance of procedural and engineered safeguards at the plant to minimize the likelihood of a significant release of a hazardous chemical, and to mitigate the effects of any release that might occur. Some highlights of our program are: 1. Process Hazard Analyses - Formal process hazard analyses (PHAs) have been performed on all plant operations involving regulated substances. PHAs are conducted by a team of personnel from a variety of plant experience backgrounds to ensure all aspects of operation are considered. During PHAs, each piece of equipment involved in the process is individually evaluated for its fitness for duty considering all expected operating conditions. Startup, shutdown and upset conditions are also considered. During PHAs, design and equipment weaknesses are investigated to eliminate the weakness or reduce its impact. Measures are in place to continuously update this information. 2. Process Design - Our processes are designed for safety in accordance with applicable industry standards and best engineering practices. Designs include, as appropriate, automatic emergency shutdown systems, pressure relief devices, ventilation systems and release sensing systems. Most operations containing chemicals are computer controlled with trained chemical operators acting as backup and monitors. Computer controls include continuous monitoring of critical operating parameters such as temperature, pressure, tank levels, flowrates and valve positions. Computer controls have inputs to detect abnor mal conditions requiring automatic shutdown and alarms. All production areas have sufficient containment, that in the event of a leak, no material will be discharged to the environment. Concrete containment dikes surround all storage tank areas. 3. Training - Operations and maintenance personnel are thoroughly trained on their job tasks, on safe work practices as they apply to their jobs, and emergency contingency actions, before they may operate or maintain equipment. They also receive refresher training periodically. Our operating and maintenance procedures, general safety procedures and emergency response procedures are fully documented and updated for any changes in plant operations. 4. Maintenance - Each item of equipment at our plant that is involved in maintaining safety or in responding to an abnormal situation is inspected, tested and/or maintained on a frequency that reflects its service and condition. 5. Management of Change - No change to equipment or procedural practices can take place at the plant without a thorough review of the implications of that change to safety. No change must adversely impact the safety built into the design and operations of our processes. Our PSM program is tuned to reflect the specific hazards of the chemicals we use. For example, our operating, maintenance, safe work and emergency procedures address personal protective equipment appropriate to the material being handled. Also, equipment is selected based on its intended service and chemical exposure. d. Five Year Accident History We have had no incidents at the Gastonia plant involving substances included in the RMP rule in the past five years. e. Emergency Response Program We have in place a written emergency response plan that we coordinate with the Gaston County Local Emergency Planning Committee (LEPC), South Gastonia Volunteer Fire Department and other local responders. BFGoodrich personnel are active in the LEPC. New personnel are trained on the plan contents and in their duties in the event of an emergency upon initial hiring. All personnel are trained on the plan contents and their duties at least annually. The plant emergency response plan meets the requirements of RMP as well as all other EPA and OSHA requirements. Internal evacuation drills are practiced at least annually. The plant evacuation alarm is tested weekly. f. The Worst-Case Release Scenario(s) and the Alternative Release Scenario(s), including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario The EPA RMP rule requires that this plan include a Worst-Case Scenario (WCS) representing all toxic regulated substances present above the threshold quantity, and one worst-case release scenario representing all flammable regulated substances present above the threshold quantity. Scenarios have been considered for each listed toxic material and one WCS for a listed flammable material. The EPA RMP rule specifies the co nditions of the WCS for toxics such that the entire contents of the largest vessel or pipeline is released in ten minutes and instantaneously begins to evaporate with no human intervention to correct the problem. The EPA requires that this scenario be modeled using the highest daily maximum temperature over the last three years. The WCS for flammable material requires a situation in which the entire contents of the largest vessel or pipeline is released instantaneously, vaporized and ignited, resulting in a vapor cloud explosion. BFGoodrich does not agree with this method of developing WCSs since the prescribed incidents are physically impossible. Nevertheless, we have prepared the following WCSs for our operations. The WCS for this facility for toxic substances is an incident involving a release of the entire 20,000-gallon storage tank of vinyl acetate. The tank is assumed to rupture and the entire contents are spilled to the surrounding concrete containment dike in ten minutes where it begins to evaporate. The EPA supplied software for release dispersion prediction calculated an endpoint distance of 0.9 miles. BFGoodrich has several safeguards to ensure that this condition does not exist including leak detection devices that continuously monitor the storage tank area for vapors, a spill containment dike equipped with a foam suppression system to blanket spilled material to minimize evaporated liquid, and employees who are trained in emergency response procedures. The WCS for flammable materials involves the entire contents of our 60,000-gallon 1,3-Butadiene tank released into the air and simultaneously ignited to form a vapor cloud explosion (VCE). The EPA-supplied software predicts an endpoint distance of 0.5 miles. All international experience with vapor cloud explosions and predictive models indicates that the physical conditions for a significant VCE can be achieved only if the flammable gas accumulates and is ignited in an area congested by obstac les such as vessels or equipment, or is released in a semi-confined area such as an indoor release. Otherwise the gas will just burn without causing an explosion. Since our storage tank is located outside with no confining structures, it is highly unlikely, if not impossible, for a VCE to occur. Furthermore, the area surrounding the storage tank contains electrical equipment that is rated intrinsically safe, meaning it is designed not to produce any source of ignition during its operation. Leak detection devices are continuously in operation in the butadiene storage area to inform employees in the event of a leak. This detection system has an audible alarm and visible readout to alert employees of any problems. EPA requires that this plan consider at least one Alternative Release Scenario (ARS) for each listed toxic substance in a process above its threshold quantity. An ARS must also be considered for flammable substances as a class. Alternative Release Scenarios considere d for inclusion in this plan must lead to toxic endpoints beyond the plant fenceline, a condition that this plant has never experienced in its over twenty year operating history. Unlike WCSs, ARSs are allowed to consider mitigative systems, such as interlocks, automatic shutdown systems, pressure relieving devices, pollution control devices, emergency isolation systems, fire water and deluge systems and passive mitigation systems such as alarm systems that alert employees to abnormal conditions that could lead to emergency situations. Therefore, Alternative Release Scenarios included as part of this plan, more realistically define the situations that may be possible if all existing safety systems and operating procedures fail. The ARSs for Acrylonitrile and Vinyl Acetate involve the release of 840 pounds in 15 minutes. The endpoint distance for each scenario is 0.2 mile and 0.1 mile, respectively. Although this situation has never occurred, it could possibly happen in the unlike ly event that a pipeline would rupture during material transfer or should a truck unloading line become disconnected. Current operating procedures would minimize the amount spilled. Personnel are trained in safe operating procedures and steps to take in emergency situations. At the truck unloading station, there is secondary containment, in the event of a spill. Truck unloading is always performed by trained BFG personnel who are required to constantly monitor the truck unloading. In the event of a spill, foam suppression systems are available to minimize evaporation of the spilled material. The plant has a highly trained team of emergency response personnel familiar with the actions to take in the event of a spill. Plant pipeline systems are routinely inspected by an outside contractor to determine their mechanical integrity. This ensures that piping systems are adequate for all operating conditions. A leak detection and repair program further insures that piping system com ponents are safe for operation. The ARS for flammable substances involves1,3-Butadiene. In the highly unlikely event that an entire railcar was involved in a fire, the endpoint distance for the possible vapor cloud explosion is estimated to be 0.2 miles. All equipment used in butadiene service is non-spark producing. All components are grounded to prevent static sparks. All electrical equipment is intrinsically safe and rated for explosive atmospheres, meaning in the event of a release of flammable vapors in the area, all equipment could operate normally without causing a source of ignition. The butadiene storage tank area as well as the railcar unloading area is constantly monitored by flammable gas monitors that have an audible alarm and visible readout to alert employees of vapor releases before explosive conditions occur. All unloading pumps are automatically shut down if any one of the sensors reaches an alarm level. The butadiene storage tank and pipeline systems are r outinely inspected by an outside contractor to determine their mechanical integrity. This ensures that the tank and piping systems are adequate for all operating conditions. Railcar unloading is always performed by trained BFG personnel who are required to constantly monitor the unloading process. BFGoodrich Gastonia personnel are active in the Local Emergency Planning Committee that is coordinated by the Gaston County Emergency Management Department. This committee reviews past emergency response situations in the county and prepares contingency plans for any emergency response anticipated in Gaston County. The committee has members who represent industrial facilities as well as emergency response personnel from local police, fire and medical response agencies. Mock drills of chemical emergencies are routinely performed. The Gaston County Emergency Management Department now has an automated phone dialing system to alert residents in the event of an emergency that requires evacu ation or other precautionary measures. This committee has been fully briefed on the contents of this facility's Risk Management Plan. g. Planned Changes to Improve Safety We expect scenarios such as these ARSs and WCSs to be highly hypothetical and unlikely because of our proven accident prevention programs and operating history. We take pride in our safety programs and safe operating performance, which has been recognized in recent years by the Chemical Manufacturer's Association, The North Carolina Department of Labor, The National Safety Council of North Carolina and the Society of Plastics Industry. We will continue to look for opportunities to improve our outstanding safety record. |