Marietta Plant - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

Executive Summary - Vinings Industries, Inc. 
Plant: Marietta, GA 
 
Vinings Industries is a chemical manufacturing company based in Atlanta, GA.  We produce products for several diverse industries including paper manufacturing, pigment mining, textile sizing, paint manufacturing, water treatment and agricultural pest control.  
 
The Marietta plant manufactures products for the paper, paint, pigment mining and textile sizing markets.  The portion of the plant that is covered by Risk Management makes acrylic polymers that are sold to companies in the above markets. The polymer production facility has been in operation for 24 years, utilizing state of the art process control instrumentation as well as emissions control units including a thermal-oxidation unit and an onsite wastewater pretreatment plant. 
 
OSHA regulations (Process Safety Management) for several years have required that multiple Layers of Protection be included during design, before startup and to continue through operations a 
nd training of all employees. These Layers of Protection are maintained today as part of our Risk Management Programs. 
 
The polymer plant uses two raw materials that are covered under Risk Management:  vinyl acetate and ammonia solution . EPA lists both of these materials as Toxics.  
 
Vinyl acetate: 
   Colorless liquid with a sharp sweet odor  
   Flammable in liquid and vapor form 
   Liquid vinyl acetate is lighter than water 
   Vinyl acetate vapor is lighter than air  
   Direct contact to skin and eyes will cause irritation 
   Inhalation of fumes can cause shortness of breath and sore throat 
 
Ammonium hydroxide solution: 
   Colorless liquid with a pungent, ammonia odor  
   Liquid ammonium hydroxide is lighter than water 
   Ammonia vapor is lighter than air 
   Contact with the eyes can result in severe irritation or blindness 
   Contact with the skin can cause burns or blistering 
   Inhalation of high concentrations can cause respiratory distress 
        
As part of Vinings' stewardship and safety programs, we reco 
gnize that vinyl acetate is also flammable. The design of storage and handling systems take all of the hazards of each material into consideration. Materials handling, from unloading through process vessels are in closed vent systems or when venting is required, is routed through scrubbers designed to minimize emissions to the atmosphere.  
 
We receive tank truck shipments of refrigerated ammonium hydroxide solution. Our storage tank is insulated and temperature controlled. 
 
The polymer reaction systems (as well as loading and unloading systems) are monitored by computers and by trained operators. Interlocks in the computer logic, for example, are designed to prevent a storage tank from being overfilled. Operator double-checks are in place to assure all valves are in the proper position and that all safety observations and checks are properly completed. 
 
All material transfers are through closed pipe systems. Vapor return lines are used in most unloading procedures to return the displac 
ed vapor to the delivery vehicle. Additionally, all reaction vessels use a series scrubber unit complete with a hydrocarbon analyzer to measure the VOC output on a continuous basis. Vent lines to the monomer storage tanks and monomer feed tanks are hard piped to the scrubber, after which residual vapors pass through the thermal-oxidation unit.  
 
Offsite Consequence Analysis:  
Worst Case Scenario - Toxic Chemical - Analysis of our processes showed the Worst Case Scenario to be the sudden and complete loss of a full tank (230,000 pounds) of vinyl acetate. The only safety precautions that Risk Management allows to be considered in the Worst Case Scenario are passive mitigation. In our case, the storage tank is surrounded by concrete dike containment. The contents of the ruptured tank would empty into the secondary containment, limiting the surface area from which vinyl acetate could evaporate. Based on EPA's Offsite Guidance, we estimate evaporated vinyl acetate would travel approximately 
0.8 miles. This distance is based on the assumption of urban terrain. Within the affected area, a population of 1,500 would potentially be affected, including residences, commercial and industrial facilities, and a National Park 
 
Alternative Scenarios:  While the alternative scenarios are still unlikely to occur, they are more likely to happen than are Worst Case Scenarios. In the Alternative Scenarios, we can presume our Layers of Protection, our safety processes, our safety programs, our safety equipment and our people will be available for response.  While these scenarios are more likely to happen than the Worse Case, and these are the scenarios that we use for Emergency Planning, our safety systems are designed to prevent them from happening. 
 
Alternative Case Scenario - Toxic #1 - Analysis of our systems indicate that a more likely toxic scenario would be continuous venting from the relief valve on the vinyl acetate storage tank because of tank over-pressurization due to a fire i 
n the containment pit below the tank. Mitigation systems include sprinkler systems, a deluge system, water curtain, foam suppression and inert padding as well as emergency shutdown systems. These mitigation systems are not used in calculating the endpoint because of the short time duration of the event. In such case, we estimate the loss to be 7,900 pounds in 20 minutes. Using EPA's Offsite Guidance, we estimate vinyl acetate would travel 0.35 miles before the concentration dispersed to a level considered by EPA to be non-hazardous. Within these areas, a population of 320 would potentially be affected, including commercial and industrial facilities, and a National Park. (Note that this estimated distance barely reaches the near border of the Park.) 
 
Alternative Case Scenario - Toxic #2 - Analysis of our systems indicate that a more likely toxic scenario would be a pipe leak discharging ammonia solution into an uncontained area. Note that while the tank or pipe may not have specific con 
tainment, the entire production area is equipped with floor drains to prevent free liquid from leaving the site. In such an incident, the loss of ammonia would be 3,700 pounds in 10 minutes. Using EPA's Offsite Guidance, we estimate ammonia would travel 0.1 miles before the concentration dispersed to a level considered by EPA to be non-hazardous. Within these areas, a population of 37 would potentially be affected, including commercial and industrial facilities. 
 
Scenarios - Flammables - We have materials at the Marietta facility that are flammable (including vinyl acetate which is considered by EPA to be Toxic and is discussed above). These other flammable materials, however, are not regulated under RMP. Regardless, we have systems in place for these flammable materials, including vinyl acetate, that are designed to prevent accidents and to respond to accidents if they occur.  
 
The polymer plant at Marietta is designed to prevent releases and to minimize hazards from flammable materia 
ls. Where flammable materials are stored or processed, inert (gas) padding systems are employed to minimize the potential for fires or explosions. In addition, vessels and piping are grounded to minimize static or electrical ignition such as from lightning strikes. 
 
In the event of a fire on the plant site, our emergency response teams are trained to evaluate the magnitude of the fire and if it is within their capability, to fight it until outside assistance arrives. Our fire fighting systems include a four team incipient Fire Brigade with a plant-wide response time of less than three minutes, 24 hours per day, seven days per week. Capabilities include water supply from two different headers coming into the plant and two auxiliary pumping systems; both with internal emergency power. 
 
Accident history: In the past five years, this facility has had no incidents with RMP regulated materials causing an offsite consequence. However, on January 29,1996, an operator inadvertently mixed two ma 
terials improperly and released sulfur dioxide to the atmosphere. Nearby businesses and residences were evacuated and seven people sought medical attention. We have since instituted processes and procedures to prevent a recurrence. 
 
In addition, we have experienced occasions when citizens have reported objectionable odors coming from the Marietta plant. There have been no reported offsite consequences. Regardless, we have an obligation to determine the source(s) of these odors and to take actions to prevent a recurrence. In each instance of an odor complaint, we have investigated the cause and as applicable, corrected the problem and/or taken actions to prevent a recurrence. An example of corrective actions designed primarily for odor control was the installation of the thermal oxidation unit in 1995 at a cost of $350,000. 
 
The goal at Vinings is to produce quality products and to produce them safely. We have systems in place that are designed to prevent accidents, to safeguard our emp 
loyees, our community and our environment. Following is a partial listing of the Layers of Protection that we employ in our everyday activities. 
 
Design: Since the inception of OSHA's Process Safety Management requirements, we used best engineering practices to assure the systems would operate as intended. All changes or additions to the processes undergo a formal review and approval procedure. This triggers hazard analysis and design safety reviews as necessary. We have concrete dikes to catch any spilled materials.  
 
All of our valve systems are designed to fail-safe. This means that in the event of computer failure or loss of electrical or air power, valves will return - open or closed as necessary - to the "safe" position. In addition, we have both backup battery systems for computers and an auxiliary generator in case of power failure. 
 
On a regular schedule, we are required to complete a comprehensive review of the hazards and operability of our entire production system. If we fi 
nd a valve, pipe, tank or pump that might fail and allow a release or an incident, we will correct it immediately.   
 
Maintenance: We have formal mechanical integrity program and preventative maintenance program in place. Tanks and piping undergo thickness testing for assessing life and to determine needs for repair or replacement before failure. Our operators will recheck equipment before operating it, after maintenance has been performed on it. Using a combination of safety and quality programs, all of our instruments are calibrated and our storage and transfer systems are tested on a regular basis. 
 
Safe Operations: Our employees are essential to the safe operation of our plant. Their training, their experience, their observations and their knowledge of how to respond to situations is the basis of safe operations. These people apply their knowledge and training in their everyday actions. All activities in the polymer plant - from unloading railcars to filling trucks with finished pr 
oducts - are restricted to trained, designated employees. 
 
Activities in polymer plant are computer aided. This means that some actions taken by an operator are checked against an internal list in the computer's memory as well as with remote sensors to make sure it is the correct action. On plant operations designated as having high risk potential, we have systems designed to automatically manage emergency interlocks that will shut down selected transfers to some vessels, shut down pumps or automatically cool vessels.  
 
The equipment and systems that contain these materials are closed; that is, the materials are contained in equipment that is designed to prevent materials from reaching the atmosphere or environment. This extends from the time we unload a railcar of raw materials until we move them through storage tanks to the processing vessels.  
 
Auditing: The Vinings Quality System at Marietta is certified according to ISO 9002 standards. While directed at quality, the training and d 
ocumentation requirements of ISO guidelines are quite similar to those for OSHA and EPA under Process Safety Management and Risk Management. 
 
In addition to the audits required by all three of these guidelines, we are regularly visited, inspected and/or audited by regulatory agencies.  
 
Emergency Response: Our operators are trained to identify unusual occurrences. We have Emergency Response Teams in place at the Marietta plant. These individuals undergo significantly more training than do operators; have cell-phone/two-way radio capabilities and a designated and fully equipped Emergency Operations Center from which to operate. 
 
In the event of an incident on the plant site, our Emergency Response Plan tells us to take the following actions: 
   An alarm system will notify all employees that an event has occurred. Monitors include automatic detectors, computer systems and visual inspection by our operators. 
The Emergency Response Team will assess the magnitude of the incident and determine 
if it is within our control. 
If the incident is within plant control a response plan will be developed.  If not, the Emergency Response Team will Shelter in Place with the plant population. 
   Operators will shut down transfer systems as they evacuate the operating portions of our plant 
   All employees will shelter in place in one of two office areas on the site  
   Designated employees will call for fire and emergency services via 911 
   We will summon our emergency response contractors 
   We will advise emergency responders of the known hazards and follow their guidance 
 
Training and preparation: Certainly all of us want to do everything we can to protect the health and well being or our employees and our community. We have our Layers of Protection in the plant; we use training exercises to further protect our employees and to reduce the impact of any releases on our neighbors.  
 
Training is extended to include local Fire and Emergency Services groups. Through these training exercises, we ar 
e developing partnerships. These partnerships allow us to gain confidence in each other's knowledge and abilities to deal appropriately with incidents. These shared roles in incident response are intended to assure the public, and ourselves, that we can and will react properly and promptly.  
 
Vinings Industries is an active member of the Cobb County Resource Council, a partnership of government and industry designed to share information, technology, equipment and resources in the event of an incident.
Click to return to beginning