H.B. Fuller - Covington Plant - Executive Summary

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Executive Summary 
1.0 Accidental release prevention and emergency response policies  
We, at the H.B. Fuller Company's Covington plant, are committed to employee, public, and environmental safety.  Our various accidental release prevention programs covering areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility demonstrate our commitment.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances as well as adhere to all applicable federal and state regulations. 
2.0 The stationary source and the regulated substance handled 
The facility's primary activity involves the polymerization of several monomers including Vinyl Acetate Monomer (VAM) and the production of water-based emulsions.  VAM is a key ingredient in the production of our emulsions and it is also a Clean Air Act Amendments (CAA) section 112(r) regulated substance.  VAM is received by truck and rai 
lcar transport and stored in three storage tanks. The raw material is subsequently metered through a series of pipes and pumps and is ultimately polymerized in the manufacturing process.  Other chemicals are combined with the polymerized monomer such as water, stabilizers, initiators, and post additives to produced the finished product emulsion.  Access to the site is restricted to authorized facility employees, management personnel and contractors.  Visitors are escorted while touring the plant. 
7 The regulated substance handled at this manufacturing facility is Vinyl Acetate Monomer; 
7 The maximum amount of VAM stored in the three storage tanks is 702,000 pounds. 
3.0 The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario 
Worst Case Scenario 
In determining our worst case scenario, we used EPA's Offsite Consequence Analysis (OCA) Guidance Reference tables and Equ 
ations to determine both the release rate and the distance to the endpoint.  The analysis assumed catastrophic failure of the VAM storage tanks when filled to capacity resulting in a release of 702,000 pounds.  The OCA Tables and Equations show that an accidental release of this magnitude would have an off-site impact.   
Passive mitigation measures currently installed to minimize the off-site impact include a large secondary containment area.  A series of tall dikes and sumps limit the exposed surface area of pooled liquid in the event of an accidental spill.  This passive mitigation system reduces the release rate to the outside air in the event of tank failure to 150 pounds per minute.  This rate represents a continuous unabated release period of almost 78 hours in order for the entire 702,000 pounds to evaporate. In our opinion, this is an unlikely event.  In addition to the passive mitigation structures described above, the three storage tank have a mechanical high-level shutoff s 
witch installed inside each vessel to automatically interrupt the VAM unloading pump once the tank capacity is reached.   
Alternative Case Scenario 
Our chosen alternative scenario assumed a mixing vessel overfilled beyond its capacity with VAM.  This alternate case presupposed maximum pump discharge rate for 15 minutes without interruption.  We chose this particular scenario because overfilling a mixing vessel has occurred previously.  This specific example results in an estimated distance to the toxic endpoint of less than .1 miles and a release rate to the outside air of 10 pounds per minute.  The resulting exposures and impacts generated by EPA's OCA model showed minimal impact to the neighboring community. 
The alternative case analysis considers the current passive mitigation measures installed at the plant to minimize the offsite impact.  These measures include sumps, dikes, and building enclosure.  Active mitigation measures such as audible and visual high level alarms (set at  
different capacities) are installed in the equipment to minimize the possibility of overfilling the mixing vessels.  In addition, there is an automatic shutoff switch installed to stop the VAM flow once the preprogrammed amount has been discharged into the vessel. 
4.0 The general accidental release prevention program and chemical-specific prevention steps 
Our Covington facility has taken all the necessary steps to comply with the accidental release prevention requirements described in 40 CFR part 68.  Our emulsion manufacturing process utilizing VAM is subject to the OSHA Process Safety Management (PSM) standard under 29 CFR 1910.119.  Our facility is also subject to EPCRA section 302 notification requirements.  The following sections briefly describe the current elements of the release prevention program in effect for the VAM polymerization process. 
Process safety information 
Our facility maintains records on safety information that describes the chemical hazards, operating paramete 
rs, and equipment designs associated with all covered processes. 
Process hazards analysis 
Our facility conducts safety studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses is the Failure Mode and Effects Analysis (FMEA).  The studies are undertaken by a team of facility personnel with expertise in engineering and process operations and are revalidated whenever necessary.  All findings related to the hazard analysis are addressed in a timely manner. 
Operating procedures 
For the purposes of safely conducting activities within our covered process, the Covington plant maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, sequence of raw material additions, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround.  The information is regularly reviewed a 
nd readily accessible to operators involved in the process. 
The plant has a training program in place to ensure that employees are competent in operating procedures associated with the VAM utilizing process.  Refresher training or operational evaluations are provided at least every year and more frequently as needed. 
Mechanical Integrity 
The facility carries out documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks include pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps.  Qualified personnel carry out maintenance operations.  These employees are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Management of change 
Written procedures are in place at the Covington plant to manage changes in process chemicals, technology, equipment, and p 
rocedures.  Process operators, maintenance personnel, or any other employee whose job tasks are affected by a modification in process conditions are promptly informed and retrained if necessary. 
Pre-startup reviews 
Pre-startup safety reviews related to new processes and to modifications in established operations are conducted at the Covington plant.  These reviews are conducted to confirm that construction, equipment, operating, and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
Compliance Audits 
The company conducts audits on a regular basis to determine whether the provisions set out under the RMP and PSM rules are being implemented.  These audits are carried out at least every 3 years and any corrective actions required are undertaken in a safe and prompt manner. 
Incident investigation 
The Covington plant promptly investigates any incident that has resulted in a reportable release of VAM.  These investigations are undertaken to ide 
ntify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of 5 years. 
Employee participation 
The plant believes that process safety management and accident prevention is a team effort.  Employees are encouraged to express their views during monthly safety meetings concerning accident prevention issues and to recommend improvements.  In addition, our employees have access to all information created as part of the facility's implementation of the OSHA Hazard Communications, PSM, and RMP rules, including information resulting from the process hazards analysis. 
On occasion, the plant hires contractors to conduct specialized maintenance and construction activities.  The Covington plant maintains a policy of informing the contractors of known potential hazards related to the contractors work and operation within our facility.  Contractors are also informed of all procedures for 
emergency response should an accidental release of VAM occur. 
5.0 Five-year accident history 
This facility has had an excellent record in preventing accidental releases.  Due to our various release prevention programs, there has been no reportable accidental releases (as defined in 40 CFR 68.42) during the last 5 years. 
6.0 The emergency response program 
The Covington plant carries a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes all aspects of emergency response including adequate first aid and available medical treatment, evacuations, and notification of local emergency response agencies.   
To ensure proper operations, our emergency response equipment such as the sprinkler system, fire extinguishers, and fire detection systems are regularly inspected and serviced.  In addition, the plan is updated to reflect any pertinent changes occurring within our process that would require a modified emergency response. 
7.0 Planne 
d changes to improve safety 
The Covington plant continues to periodically evaluate the safety effectiveness of its equipment and total process through our preventive maintenance program, process hazards analysis updates, and the management of change procedures.  These programmatic structures, as well as suggestions generated by employee involvement teams have led to several changes improving safety overall.  We plan to continue this safety enhancement process and implement appropriate improvements whenever possible.
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