GE Plastics - Burkville - Executive Summary |
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EXECUTIVE SUMMARY 0.1 INTRODUCTION GE Plastics-Burkville has a strong record of commitment to environmental protection and safety throughout its 12 years of operation since start-up. We have developed comprehensive systems and programs to assure the safety of our employees and the surrounding community. We operate in compliance with the Occupational Safety and Health Administration's Process Safety Management guidelines, a rigorous set of standards that govern our daily process safety control methods and behaviors. These guidelines have been adopted to satisfy, in part, the stated policy of GE Plastics to safely manage our site operations and to take care of the people who work here and the community around us. We recognize that any less commitment would weaken our ability to provide jobs for our employees and to be a part of the economy of Central Alabama. This Risk Management Plan is a continuation of that effort. It shows solid integration of our plant emergency response resour ces and communication channels with those of the community. Our intensive ongoing internal reviews and OSHA's external audit process continue to validate the strengths of the programs we have in place. We have been certified by OSHA under its Voluntary Protection Program (VPP) as a "STAR" site, the highest certification OSHA gives, and one held by fewer than 300 U.S. plants. 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 plant, please contact our Community Relations Representative at (334) 832-5650. 0.2 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Our company is committed to operating safe and environmentally sound chemical and plastics production facilities everywhere we do business. Protection of our environment, our neighbors and our employees is the highest priority. Th is ongoing commitment to worker and public safety is demonstrated through resources invested for safe design, operation, and maintenance of our facilities. The GE Plastics-Burkville facility uses in its manufacturing processes some raw materials that are classified as toxic by the EPA. While we are committed to 100% compliance with governing laws, regulations, and engineering standards, as well as systematic assessments to manage and maintain safe operation with these materials, we routinely go far beyond the regulatory requirements. Our operating practices and procedures provide for numerous controls that are implemented to prevent an accidental release of a chemical. In the unlikely event of a major release, our trained on-site emergency response organization would be activated. This organization includes a fire brigade as well as medical and chemical emergency response teams staffed with GE employees who have trained collectively for thousands of hours. Many of these employees s erve in their community fire and emergency response organizations, devoting much of their personal time to additional drills, training and community response. The Burkville facility has contracted with Louisiana State University's Fireman Training Academy in providing the highest level of Emergency Response training and drills offered in the United States. OSHA recognizes LSU's Fireman Training Academy as one of the top Industrial Emergency Response Training organizations in the country. LSU has conducted training for our facility in all areas of chemical emergencies, industrial fire fighting and emergency management. Our Fire Brigade visited LSU's state-of-the-art live fire training facility in Baton Rogue, La. in 1999 to receive additional training and gain valuable experience in the fighting of large industrial fires. A review of our emergency response program was made as part of the OSHA STAR review in 1998 and was found to fully meet all the OSHA emergency response requirements. 0.3 DESCRIPTION OF THE FACILITY AND REGULATED SUBSTANCES The GE Plastics-Burkville plant is located about 15 miles west of Montgomery. The 420 members of the GE Plastics-Burkville Team manufacture engineered plastics, marketed under the trade name LEXANR. Our products are used in industries including automotive, electronic, computer, compact disc and large appliances. Workplace safety and environmental protection are part of the GE Plastics culture and record. Of the initial $325 million GE investment in the plant, nearly 25% went to safety and environmental systems. GE has now invested some $1 billion in the plant for expansion, capital improvement, safety and environmental protection. Demonstration of this safety and environmental commitment is reflected not only in the VPP Star designation but also in many examples including: 1.) reduction of emissions by 60% while increasing production fourfold; 2.) Twelve years of operating without exceeding the plant's water permits [Twice th e plant has received the Award of Excellence for industrial wastewater treatment in Alabama]; and 3.) Recognition in 1997 and 1998 by the Chlorine Institute for safety performance in the Brine Recovery Unit. Completed in 1987, the plant occupies about 300 acres of a 6300 acre site along the Alabama River. Under GE's stewardship, this large Alabama site has been certified as a National Wildlife Habitat. The Wildlife and Land Management Committee, an employee volunteer group, pursues programs, including reforestation, pond management and bluebird trails. The Burkville, AL plant uses two chemicals that are regulated under the EPA's Risk Management Program (RMP) rule. These are: Chlorine & Phosgene, both are regulated toxic substances. Chlorine and Phosgene are raw materials 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 imp acts 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 10-minute release of the contents in the largest single vessel on-site that results in the greatest distance to the EPA-defined level-of-concern. This worst-case scenario at the Burkville site would involve the catastrophic failure of a storage tank containing chlorine liquid and the simultaneous failure of the ventilation and control system that prevents chlorine emissions reaching the atmosphere from the building enclosure. The quantity of material released is assumed to be 300,000 pounds of chlorine. Under this scenario, the chlorine liquid is assumed to completely evaporate and the vapors dispe rse in the direction of the prevailing wind. According to EPA guidelines, exposure to chlorine can occur without serious health effects at levels up to 3.0 parts per million (0.0087 mg per liter) for approximately one hour. A scenario using more realistic assumptions involves an upset in the chlorine manufacturing process. EPA defines this as the Alternative Release Scenario (ARS), typically used for emergency planning purposes. As much as 1200 pounds of chlorine could be released to the atmosphere over a 25-minute period. The shutdown and isolation of this manufacturing process would mitigate the impact of this scenario. The alternative release scenario for phosgene involves the rupture of a three-inch pipeline containing up to 3% phosgene gas. As much as 48 pounds of phosgene could be released over a 20-minute period. The shutdown and isolation of this pipeline would mitigate the impact of this scenario. 0.5 GENERAL ACCIDENTAL RELEASE PREVENTION / CHEMICAL-SPECIFIC PREVENTIO N STEPS GE Plastics 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 program requirements of the RMP. Some of the many, specific safety features to prevent a chemical accident include: 7 Computer-controlled safety systems on the phosgene and chlorine manufacturing processes 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 release - including annual training; 7 State-of-the-art building enclosures around ch lorine and phosgene equipment to contain a leak; 7 Dedicated emergency safety equipment that cleans or "scrubs" chlorine or phosgene gas in the event of an emergency release from the manufacturing process; 7 Dedicated control equipment that continuously cleans or "scrubs" chlorine or phosgene gas from process vent systems; 7 Transfer of chlorine and phosgene liquid is done within a double-walled or "pipe-within-a-pipe" system to prevent leaks to the atmosphere; 7 Phosgene and chlorine gas sensors to detect and warn of a release; 7 Extensive safety information about the processes reviewed with employees and contractors; 7 Written operating procedures that include emergency response actions; 7 Comprehensive employee and contractor training programs to promote consistent safe work-practices; 7 Maintenance programs to ensure ongoing equipment reliability - including equipment testing and inspection; 7 A safety procedure to review proposed plant modifications before they are implemented f or 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, 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 The Burkville, AL site has an outstanding record of accident prevention 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 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, one such incident occurred at the plantsite. On November 10, 1997 one GE Plastics employee was exposed during an incident involving a release of less than one pound of chlorine from an open drain. This exposure aggravated a previous respiratory condition the employee had and required medical attention. The employee returned to work the next day. There was never any danger to the community or anyone else beyond the immediate area of the leak, and there was no environmental impact from this incident. The cause for the incident was identified and actions were put in place to prevent future occurrence. 0.7 EMERGENCY RESPONSE PROGRAM The Burkville, AL site maintains a written emergency response program designed to protect workers, the public, and the env ironment in the event of a major accidental release. All of our employees and contractors 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 Tactical Response Team works closely with area hospitals and other response organizations in the surrounding community. For example, the facility has contracted Louisiana State University Firemen Training Academy to train the Tactical Response Team in Hazardous Materials Emergency Response, Industrial Fire Fighting, and in aiding the site to perform emergency drills, organized and directed by the GE Emergency Response Teams. The site works with the community emergency response agencies to conduct drills involving our chemicals. These drills are designed to test our operations, our Response Team members, and the community response agencies in the proper response to such an event. Ongoing training exercises are important to the compan y'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. GE personnel have helped develop emergency preparedness plans for local communities. In addition, they are members of local emergency planning and emergency preparedness groups, and are active members of the surrounding volunteer fire departments. 0.8 PLANNED CHANGES TO IMPROVE SAFETY GE Plastics is committed to continuously improving the overall safety and environmental performance record at the Burkville, AL 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 Ongoing evaluations to identify ways to continuously improve our safety systems; 7 Implementing behavioral training programs for employees to further reduce the chance of human error leading to a workplace injury or an accidental release; and, 7 An ongoing employee exposure monitoring and reduction program for phosgene and chlorine. |