AlliedSignal Elizabeth Plant - Executive Summary |
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The AlliedSignal Elizabeth Plant is a manufacturing facility located in Elizabeth, New Jersey. It is part of the Polymers Business Unit of AlliedSignal Inc. Headquartered in Morris Township, New Jersey, AlliedSignal is an advanced technology and manufacturing company serving customers worldwide with aerospace and automotive products, chemicals, fibers, plastics and advanced materials. With 1998 sales of approximately $15 billion, the company ranks among the top 100 of the Fortune 500. AlliedSignal has approximately 70,500 employees at 300 facilities in 40 countries. AlliedSignal operates eleven major businesses: Aerospace Equipment Systems, Electronic and Avionic Systems, Aerospace Marketing Sales and Services, Federal Manufacturing and Technologies, Polymers, Specialty Chemicals, Electronic Materials, Automotive Products Group, Turbocharging Systems, Truck Brake Systems, and Friction Materials. More information may be found about AlliedSignal at its Web Page: www.AlliedSignal.com. It is the world wide policy of AlliedSignal to design, manufacture, and distribute its products and to handle and dispose of materials throughout their life cycle in a manner that protects the environment and safeguards employees, customers, and the public from unacceptable risk. This policy is described in more detail in AlliedSignal's Health, Safety and Environmental Policy, which can be found on its web page. The Elizabeth Plant participates in the Responsible Care program of the Chemical Manufacturers Association. The Community Awareness and Emergency Response Code of Responsible Care brings chemical plants and local communities together through communications and cooperative emergency planning. The Process Safety Code of Responsible Care is designed to prevent fires, explosions, and accidental chemical releases. The code requires safety audits, inspection and maintenance programs, and safety training for employees and contractors. Facilities are encouraged to listen to the concerns of the community and to consider these concerns when designing and implementing process safety systems. The AlliedSignal Elizabeth Plant is a fluoropolymer resin manufacturing facility located on North Avenue near the Elizabeth Seaport. The plant employs 47 people, and operates 24 hours per day, seven days a week. The product that the facility manufactures is a plastic resin that has excellent moisture barrier properties. The resin pellets manufactured at the Elizabeth plant are shipped to another AlliedSignal plant where they are extruded into a clear film. This film is then used primarily in the manufacture of pill blister packs used to package individual doses of medication by pharmaceutical companies. The facility's Aclon resin manufacturing process consists of polymerizing a mixture of trifluorochloroethylene and vinylidene fluoride. Both of these chemicals are listed in the RMP Rule's list of regulated substances under the flammable section. The AlliedSignal Elizabeth Plant's s torage and use of trifluorochloroethylene and vinylidene fluoride exceeds the RMP Rule's threshold quantity of 10,000 pounds and therefore the Aclon Process is covered under the RMP Rule. In accordance with the requirements of the RMP rule, a description of the following seven elements is provided for the AlliedSignal Elizabeth Plant. 1. Accidental Release Prevention and Emergency Response Policies: It is the policy of the AlliedSignal Elizabeth Plant to operate a safe and environmentally sound facility by identifying and controlling health, safety and environmental risks related to its operations; by designing its processes to protect people, property, and the environment; by conducting audits and continually reviewing and improving programs for safety, health and environmental excellence; and by establishing processes to assure that all laws and regulations applicable to its operations and products are known and observed. The accidental release prevention and emergency response po licy associated specifically with the Plant's use of trifluorochloroethylene and vinylidene fluoride involves the integration of safety devices and technologies inherent in the design of the process, safe operational procedures and management practices, annual operator training, the preparation and testing of site emergency response plans, the maintenance of onsite emergency response equipment, a professionally trained emergency response team, a minimum of two emergency response drills per year, a gas detection system with sensors throughout the process area that will detect any leakage of hazardous materials, and coordination and communication of our emergency response plan with the City of Elizabeth Office of Emergency Management. 2. The Stationary Source and Regulated Substances Handled: The AlliedSignal Elizabeth Plant uses trifluorochloroethylene and vinylidene fluoride in the manufacture of Aclon plastic resin. Both materials are stored and handled in quantities that exceed th e threshold quantities specified in the RMP rule. The site's stationary source of trifluorochloroethylene consists of bulk storage and process distribution equipment located on the eastern side of the Polymers building. Trifluorochloroethylene is received on site via a tank truck and unloaded by trained plant operators to an aboveground storage tank. The maximum capacity of the trifluorochloroethylene tank is 100,000 pounds. The site's stationary source of vinylidene fluoride consists of bulk storage and process distribution equipment that is also located on the eastern side of the Polymers building. Vinylidene fluoride is received on site via a tube trailer. The tube trailer also serves as the bulk storage tank. The vinylidene fluoride tube trailer consists of three individual cylinders for a total storage capacity of 12,000 pounds. Both the trifluorochloroethylene and vinylidene fluoride are hard piped to the Aclon process reactors located inside the Polymers building. 3. Worst Case and Alternative Release Scenarios: The worst case scenario for the Elizabeth plant is the failure of the trifluorochloroethylene bulk storage tank resulting in the release of 100,000 pounds of material and vapor cloud explosion. The consequence analysis performed in accordance with the RMP rule indicates that the effects of the explosion are limited to within the confines of the fence line of the plant. No public or environmental receptors outside of our property line would be affected. No alternative release scenarios were performed for trifluorochloroethylene since the worst case scenario does not cross the plant's fence line. As a result of the offsite consequence analysis findings for trifluorochloroethylene and vinylidene fluoride, the AlliedSignal Elizabeth Plant meets the eligibility requirements for Program 1 status under the RMP rule. 4. General Accidental Release Prevention Program and Chemical Specific Prevention Steps: The general accidental release prevention progra m at the AlliedSignal Elizabeth Plant for both the trifluorochloroethylene and vinylidene fluoride consists of the following elements: A. An established Process Safety Management System for oversight and control of the Aclon Process. B. Development and implementation of accurate standard operating procedures for safe operation and maintenance of the process. C. An ongoing mechanical integrity program that insures critical process equipment is designed, constructed, installed, tested and maintained in accordance to applicable standards and codes. D. Performance of Process Hazard Analysis with prompt resolution of any recommendations. E. The use of safety shutdowns, excess flow valves, pressure relief valves, interlocks, gas detection systems, process monitoring and distributed control systems. F. Management of Change procedures. G. Incident investigation procedures. H. Pre-startup safety reviews. I. Annual operator classroom training and written testing. J. Leak detection sensor s to alert operators immediately of leakage of hazardous materials so that appropriate, preplanned emergency response actions can be taken. K. Only trained AlliedSignal employees handle trifluorochloroethylene and vinylidene fluoride. Chemical Specific Prevention Steps: A. Developing an understanding among the operators for the hazardous properties of both trifluorochloroethylene and vinylidene fluoride, the process chemistry and safe operational limits such as temperatures, pressures, and flows. B. Understanding the consequences of unsafe chemical handling, process deviations and inadvertent mixing of incompatible chemicals. C. Knowledge of the requirements, capabilities and limitations of both personal protective and emergency response equipment. D. Designing the process technology and equipment based on a thorough understanding of the hazards of trifluorochloroethylene and vinylidene Fluoride. 5. Five Year Accident History: No accidental releases covered by the RMP regulation o f either trifluorochloroethylene or vinylidene Fluoride have occurred at the AlliedSignal Elizabeth Plant in the previous 5 years. 6. The Emergency Response Program: The AlliedSignal Elizabeth Plant has an emergency preparedness planning and response program designed to deal with accidental releases and other unplanned events associated with trifluorochloroethylene and vinylidene fluoride. The site has a written Emergency Action Plan that addresses various types of contingencies including specific actions in response to scenarios involving the release of hazardous materials. The plan provides for both internal site and external community emergency notification with established calling procedures. The plan addresses emergency health care, evacuation and assembly areas, emergency responsibilities, response and control procedures, and emergency response equipment. The plan also provides for an incident command system to direct and coordinate response activities. The plan has been coordi nated with the City of Elizabeth Office of Emergency Management, City of Elizabeth Police, and City of Elizabeth Fire departments who would direct all offsite community response activities. The AlliedSignal Elizabeth Plant maintains its own professionally trained Emergency Response Team that is knowledgeable and prepared to respond to incidents involving the release of hazardous materials. Plant emergency response drills are conducted at least two times per year to insure readiness. Post drill critiques are conducted to identify any deficiencies observed in the implementation of the emergency action plan. 7. Planned Changes to Improve Safety: A Process Hazard Analysis of the AlliedSignal Elizabeth Plant's Aclon process was completed in March of 1998. In addition, an audit of the Aclon process was conducted in June of 1998 by the New Jersey Department of Environmental Protection. As a result of these systematic safety reviews, several action items were identified and implemented to i mprove upon the existing safeguards of the Aclon process and to further reduce the potential for an accidental release of hazardous materials. Process Hazard Analysis are reviewed and revalidated every five years. The New Jersey Department of Environmental Protection conducts a comprehensive safety review of the Aclon process every year and findings are used for continuous safety improvement and risk reduction. |