Uinroyal Chemical Company - Painesville Plant - Executive Summary |
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EXECUTIVE SUMMARY for the RISK MANAGEMENT PLAN of UNIROYAL CHEMICAL COMPANY, INC. PAINESVILLE, OHIO ACCIDENTAL RELEASE AND EMERGENCY RESPONSE POLICIES The company corporate position has been and continues to be one of maintaining the safety of its employees and the general public. The Painesville Plant maintains an Emergency Response Team and has complied with federal requirements under the Process Safety Management program. Recognizing the growing public concern with chemical exposure and being a long-standing member of the Chemical Manufacturing Association, Uniroyal Chemical - Painesville has been a charter member of Lake County Local Emergency Planning Commission (LEPC). Also, Uniroyal Chemical - Painesville was a charter member of the Painesville Township Community Advisory Panel (CAP). Uniroyal Chemical - Painesville has been a leader in both of these organizations for nearly 10 years. The following programs were already in place at the plant prior to the promulgation of the RMP regulation: Operator training and certification, Safety Incentive Program, On-going Maintenance Safety Training, On-going Staff Safety Training, Emergency response training, Routinely updated operating procedures, Computers and computerized control systems, Emergency control / shutdown devices / interlocks, Equipment / piping safety controls, Warning alarms, Regular safety checks, Equipment inspections, Management of change controls, Hazard reviews, and Process Hazard Analyses. FACILITY DESCRIPTION and BACKGROUND Uniroyal Chemical - Painesville (formerly U. S. Rubber Company) established a presence in Lake County in 1949 when a newly constructed vinyl chloride and polyvinyl chloride (PVC) plant was purchased from Glenn L. Martin. Production of PVC was the central focus at the site and expansions continued through mid-1960. Vinyl Chloride monomer was produced at the plant until the early 1960's. This part of the operations was moved to Geismar, Louisiana as part of a joint venture with Borden to produce the monomer. PVC was produced at the plant until 1977 when Uniroyal exited the business. A major expansion for the site occurred in 1965 when the company moved production of nitrile rubber (NBR) to Painesville. The new NBR plant was built at the same time as the last PVC expansion. In the mid-1960's, the capacity of the plant was rated at 100MM pounds of PVC annually and 25MM pounds of NBR annually. In 1979, the NBR plant was expanded to a capacity of 40MM pounds annually. As of early 1997, over 1 billion pounds of NBR (Paracril) and NBR/PVC blend (Paracril OZO) had been produced at the Painesville site. NBR is used in the manufacture of hose, sponge, shoe soles, seals, and gaskets. RMP REGULATED SUBSTANCES Three chemicals covered by the RMP regulation are in use at the plant. These chemicals are Anhydrous Ammonia, Acrylonitrile, and Butadiene. TOXIC RMP REGULATED SUBSTANCES Anhydrous Ammonia is unloaded from a specially designed tank t ruck. This chemical is used as a refrigerant in the process building. The total amount of anhydrous ammonia in the cooling system is about 28,000 pounds, most of that is held in three reservoir tanks on the roof of the process building. Since the cooling system is a closed system, the anhydrous ammonia is transferred from truck to the system very infrequently. Acrylonitrile (AN) is unloaded from railcars into a 30,000 gallon tank. This tank is dedicated to AN storage and is located in a tank farm. Unloading takes place on a regular basis, about two or three times per week. AN is pumped (via overhead line) from the tank farm to the process building where it is contained in a weigh tank prior to charging the reactors. AN is one of two monomers which are the building blocks in the polymerization of nitrile rubber. FLAMMABLE RMP REGULATED SUBSTANCES Butadiene (BDE) is also unloaded from railcars on a regular basis. BDE is stored in an 80,000-gallon horizontal tank, which is in a separate diked area. There could also be as many as six railcars of BDE on site. BDE is pumped from the pure BDE storage tank to a 10,000-gallon ?day tank? where it is blended with recycled BDE from the process building. BDE is pumped (via overhead line) from the ?day tank? to the process building where it is contained in a weigh tank prior to the charging of the reactors. BDE is one of the two monomers that are the building blocks in the polymerization of nitrile rubber. WORST-CASE AND ALTERNATE RELEASE SCENARIOS The off-site consequence analyses of these scenarios was performed using the RMP*Comp modelling software. Population estimates were obtained through the Lake County Emergency Planning Commission and adjusted by examining aerial photographs of the region. WORST CASE - Toxics The toxic worst case was found to be a catastrophic failure of the 26,500-gallon acrylonitrile storage tank. The scenario considered here was the instantaneous release of the entire contents of the tank into a concrete dike surrounding the tank. A toxic endpoint of 0.076 mg/l is reached within a radius of 1.1 miles around the tank. This radius includes a residential population of about 2,600 people. No environmental receptors, as defined in the RMP regulations, were noted within this radius. WORST CASE - Flammables The flammable worst case was found to be the vapor cloud explosion of a full 80,000-gallon butadiene tank and five nearby railcars, each containing about 20,000 gallons of butadiene. The estimated distance to a 1 psi overpressure point was 0.8 miles from the center of the explosion. This radius includes a residential population of about 750 people. No environmental receptors, as defined in the RMP regulations, were noted within this radius. ALTERNATE CASES - Toxics Two alternate cases were considered for the toxic substances, acrylonitrile and anhydrous ammonia. For acrylonitrile, the alternate case considered was the rupture of a 2-inch transfer line f lowing at 210 gallons per minute for ten minutes. It was estimated that this would result in the discharge of about 14,200 pounds of acrylonitrile into a diked area over ten minutes. The evaporation of this material would produce a toxic endpoint of 0.076 mg/l at a distance of 0.3 miles from the point of pipe rupture. No residences or environmental receptors are within this radius. For anhydrous ammonia, the alternate case considered was the rupture of a 2-inch transfer line flowing at 200 gallons per minute for ten minutes. It was estimated that this would result in the general discharge of about 13,000 pounds of ammonia. The evaporation of this material would produce a toxic endpoint of 0.076 mg/l at a distance of 0.3 miles from the point of pipe rupture. No residences or environmental receptors are within this radius. ALTERNATE CASE - Flammables The flammable alternate case considered was a vapor cloud explosion resulting from the rupture of a two-inch pipe transfer line flowing at 335 gallons per minute for 10 minutes. The estimated distance to a 1 psi overpressure point was 0.1 miles from the center of the explosion. No residences or environmental receptors are within this radius. ACCIDENTAL RELEASE PREVENTION PROGRAM As a member of the Chemical Manufacturers Association and a practitioner of responsible care, Uniroyal Chemical created and implemented many programs to reduce the likelihood of the accidental release of hazardous materials at its plant. These programs are outlined in the Accidental Release and Emergency Response Policies section of this Summary. Outstanding among these programs are the Process Hazard Analyses (PHA) performed to comply with OSHA's Process Safety Management regulations. These PHA's address specific detailed elements of the RMP-covered process. FIVE-YEAR ACCIDENT HISTORY No accidental releases of RMP-regulated substances has occurred at the Uniroyal Chemical Painesville plant within the last five years. THE EME RGENCY RESPONSE PROGRAM The emergency response plan (ERP) of Uniroyal's Painesville plant is on file with the Lake County Emergency Planning Committee and Central Dispatch (911). The ERP includes the following elements: * Procedures for informing public and response agencies of a release * Documentation of first aid and emergency medical treatment * Procedures and measures for emergency response after a release * Procedures for the use of emergency response equipment * Employee Training * Review and update procedures * Coordination with local agencies PLANNED CHANGES TO IMPROVE SAFETY There will be no bulk storage of RMP-regulated chemicals at the plant after July of 1999. Production activities will cease by July 16, 1999. RMP RISK MANAGEMENT PLAN UNIROYAL CHEMICAL - PAINESVILLE, OHIO PLANT JAS:vlm 05-11-99 |