Bayer Corporation - New Martinsville Plant - Executive Summary |
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BAYER CORPORATION NEW MARTINSVILLE PLANT June 13, 1999 Executive Summary for the Risk Management Rule 1. Accidental Release Prevention and Emergency Response Policies Bayer Corporation is committed to the principles of Responsible Care which emphasize operating in a safe and environmentally correct manner. Management systems are in place to assure all facilities are complying with these principles. There are Corporate Engineering Standards and Health, Environment and Safety Guidelines which address every aspect of Risk Management from design of intrinsically safe processes and use of layers of protection to incident tracking and program audits. Bayer Corporation is the North American subsidiary of Bayer, AG, which is headquartered in Leverkusen, Germany. Bayer Corporation has its own corporate structure, policies and procedures which are consistent with those of the parent company, but are customized to meet US regulations and standards. Bayer AG has established guidelines for Responsible Care in Environmental Protection and Safety, which includes a Directive for Process and Plant Safety that all Bayer facilities world-wide are expected to follow. It provides guidance for safe process design and operation. In the US, Bayer Corporation is an active member of the Chemical Manufacturer's Association Responsible Care Initiative. Bayer has implemented all six codes of management practice which have been verified in practice by a third party audit. Bayer Corporation has a Corporate Health, Environment and Safety Policy which states that it is the corporation's responsibility to protect the environment and the health and safety of its employees, customers and communities. This is a primary responsibility, of equal importance to any other business objective. This is supported in the corporation's Vision, Values and Beliefs, which emphasize applying technical expertise to advance our business while assuring the safety and protection of our employees, customers , communities and the environment. The Bayer Corporation New Martinsville facility has implemented all of the corporate Health Environment and Safety Policies and Guidelines through site policies and procedures. These include site Safety and Health Procedures, Emergency Response Procedures, Process Safety Management Procedures, Hazard Communication Procedure and Risk Management Procedure as well as safety plans in the individual production unit SOPs. In addition, the Bayer New Martinsville facility uses the following measures to assure the safety of our chemical processes: ENGINEERING and DESIGN 7 Detailed operating procedures 7 Special equipment standards 7 Special flanges, piping, valves 7 Remotely operated isolation valves 7 State of the art computerized controls 7 Redundant & energy protected controls 7 Control Room protection during emergencies 7 Inventory minimized for hazardous materials 7 Continuous improvement of processes & equipment 7 Hazard review for all changes 7 Colo r coding and labeling of piping & vessels 7 Dikes and curbs to contain spills 7 Vacuum system for equipment preparation 7 Emergency tank to contain system upsets 7 Redundant emergency decomposition systems 7 Spot ventilation system 7 Continuous process analyzers 7 Production units designed to withstand natural disasters 7 Active phosgene safety committees, Plant, Corporation, Industry (CMA) DETECTION 7 Perimeter monitoring 7 Personal Dose Badges 7 Control room air intake monitoring 7 Portable monitors for leak detection TRAINING 7 Refresher and safety training for all employees 7 New employee qualification requirements 7 Emergency response drills 7 Specialized maintenance skills training 7 Worker certification programs 7 Off-site specialized training for emergency response teams INSPECTIONS and SAFETY REVIEWS 7 Incident investigations and reviews 7 Systematic equipment inspection 7 Critical instrument and pressure relief valve inspections 7 Process Hazard Analyses every 5 years 7 F ugitive emissions monitoring program 7 Regular safety audits of all operating units 7 Tracking system for recommendations MEDICAL MANAGEMENT 7 Certified EMT's on each shift 7 Physician on site 2 days per week 7 Physician's Assistant and nurses on dayturn 7 Medical procedures coordinated with local hospitals MITIGATION 7 Release containment equipment and materials at each unit 7 Neutralization and decontamination procedures 7 Steam/ammonia curtains for phosgene releases 7 Foam vapor suppression capability EMERGENCY RESPONSE 7 Trained emergency response teams 7 Written emergency action plans 7 Emergency teams maintained on all shifts 7 Emergency alarm systems for units, plant, and community 7 CAER Emergency Response Plan 7 Coordination with NORIMAC, LEPC, Local Agencies EMPLOYEE PARTICIPATION 7 Annual reviews of operating procedures 7 Bayer employees make up 100% of emergency teams 7 Employees participate on incident investigation teams 7 Union employee safety trainers 2. Facility D escription and Regulated Substances Handled The primary activities at the New Martinsville facility are the manufacture of polyurethane intermediates and iron oxide pigments. The polyurethane intermediates include aromatic isocyanates like toluene diisocyanate and its precursors dinitrotoluene and toluene diamine. Polyether and polyester polyols are also produced. The iron oxide pigments unit also produces aniline. The New Martinsville facility uses or stores seven of the RMP listed chemicals on the site as of June 21, 1999. A nitric acid production unit, which has been in operation for the past 32 years, is being shutdown prior to that date, so ammonia and nitric acid, which were in the original off-site consequence analysis, are not included in this submission. Hydrazine was also included in the original off-site consequence analysis, since the site uses hydrazine hydrate in the SPU Unit. However, subsequent analysis of the process parameters found that the vapor pressure of h ydrazine in the process never reaches 10 mm Hg, therefore it does not qualify as a covered process. Of the seven chemicals covered, five are raw materials, one is an intermediate, and one is a finished product. All seven chemicals were modeled using worst case release parameters as a screening exercise to determine the worst case scenario for the facility. Phosgene was determined to be the worst case scenario chemical followed in order of potential off-site impact by ethylene oxide, chlorine, formaldehyde, propylene oxide, ethylene diamine, and toluene dissocyanate. 3. Worst Case Scenario for the Facility The worst case release scenario for the New Martinsville facility is the rupture of the phosgene solution vessel in the TDI production unit. This vessel could contain up to 40,000 pounds of 50 % phosgene solution. Because of the low storage temperature and the solution concentration, the release to the atmosphere through evaporation from a pool is calculated at 146 lb/minute ove r a 1-hour release. Using dispersion modeling (PHAST Software), this results in an endpoint distance of approximately 14.6 miles. The toxic endpoint (ERPG-2)_for phosgene is 0.02 ppm. This release assumes no mitigation other than containment in a dike. 4. Alternative Release Scenarios Alternative Scenarios were developed for all of the RMP chemicals. The alternative scenario for phosgene has the largest potential impact distance of the group. In this scenario it is assumed a leak of phosgene solution develops from the phosgene solution feed system, about 2600 pounds of 50% phosgene solution is released into the diked area. However, mitigation limits the release of phosgene to the atmosphere to a total of 466 pounds. Mitigation in this case includes immediate activation of the steam ammonia curtain, and isolation of the line and neutralization of the solution in the dike within 20 minutes. Under typical weather conditions as suggested in the RMP Offsite Consequence Analysis Gui dance (6.7 mph winds, 77 degrees F, Stability Class D) the distance to the ERPG-2 concentration is 0.73 miles. 5. Accidental Release Prevention Program and Chemical-Specific Prevention Steps The New Martinsville Plant complies with all elements of the OSHA PSM Rule and the EPA RMP Rule. There are safety procedures, standard operation emergency procedures, accident investigations, hot work and line opening permits, extensive training programs, on-site emergency response teams, vessel inspection programs, and experienced personnel both in the salaried and hourly workforce. Bayer is active in phosgene safety initiatives including a corporate phosgene safety committee, Bayer worldwide phosgene safety committee, and is an active member of the CMA Phosgene Safety Panel that deals with phosgene safety issues on an industry-wide basis. 6. Five Year Accident History There have been no releases in the past five years that had an off-site consequence. A small phosgene release within the p lant resulted in an OSHA Recordable Accident in 1996. The release was less than one pound and the individual was not wearing correct respiratory protection. The largest phosgene release on record was 1400 pounds from a hot tower leak in 1988. In that incident all but 50 pounds of the phosgene was neutralized by the steam ammonia curtain, soda ash and lime. There was no offsite impact or phosgene related injury from that release. Furthermore, there has never been any offsite impact from the New Martinsville facility resulting from the release of chemicals listed in the rule. 7. Facility Emergency Response Program The New Martinsville facility Emergency Response System consists of volunteer emergency response teams scheduled on each rotating shift. There are 128 emergency response team members. They receive four hours on-site training monthly as well as off-site training in specialized subjects, such as fire fighting, rescue, incident command and Hazmat. An E-Team organization provides secondary support and is staffed by Technical and Managerial Personnel. The E-Team's main function is to assist and advise the Emergency Response Teams and communicate with outside agencies. The plant belongs to an industrial mutual aid group called NORIMAC (Northern Ohio River Industrial Mutual Aid Council) that provides mutual aid between the various industries, government agencies, and service organizations in the area. Community warning sirens are placed in residential areas within 2 miles of the plant and have been in operation, as part of the CAER program, for more than fifteen years. 8. Planned Changes to Improve Safety The RMP rule has provided a springboard to upgrade emergency response plans and improve training for all of the hazardous chemicals listed. The New Martinsville facility is implementing the incident command system for site emergencies, coordinating area emergency response plan improvements through the Marshall / Wetzel LEPC, and actively engaging in community dialog with groups, such as the Bayer & PPG Community Advisory Panel, to improve community understanding of the potential risks from the chemical plants. Bayer has made a concerted effort to reduce the quantity of hazardous materials stored or handled at any one time. The two most prominent examples are the elimination of chlorine railcars at the New Martinsville facility in 1991 by constructing a pipeline for gaseous chlorine from the neighboring PPG plant. This minimized the total amount of chlorine available to be released and allows for quicker isolation and control in case of leaks. The amount of phosgene on-site is also minimized by systems that make phosgene only as it is needed. The lifetime of phosgene in the process is estimated at only twenty minutes. Handling phosgene in solution further reduces the opportunity for high concentrations to be released in the event of small spills. All of these activities are in concert with the principles of Responsible Care under which this facility and Bayer management operate. |