Kodak Park Site - Executive Summary |
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RMP Executive Summary Kodak Park Site Release Prevention & Emergency Response Policies Eastman Kodak Company has a well established Health, Safety and Environment (HSE) program with an extensive set of policies and procedures to ensure regulatory compliance and protection of human health and the environment. The corporations environmental management system has been registered to the ISO 14001 standard, and the Kodak Park (KP) site is currently seeking registration to the same standard. This registration involves extensive audits of policies and procedures by an independent registrar. KPs RMP Program is modeled after its OSHA Process Safety Management Program that has been in existence for a number of years. The sites Emergency Response policies are primarily contained in its Emergency Response Reference Guide, which is an extensive document containing its codes of management practice as well as policies on emergency planning, risk analysis and communications. The KP site He alth, Safety & Environment policy states that the site is committed to health, safety and environmental excellence through compliance with regulations and corporate initiatives, prevention of pollution and continual improvement of health, safety & environmental performance. Stationary Source & Regulated Substances Stationery Source The stationary source involved is the chemical and photoprocessing solution manufacturing facilities located at the KP site of the Eastman Kodak Company. KP is the largest photographic manufacturing facility in the world and the largest industrial complex in the northeastern United States. The Kodak Park plant site is located on more than 1,300 acres, and stretches nearly 4 miles in length through the City of Rochester and the Town of Greece in New York State. Regulated Substances The KP site has 2 materials that require the submission of an RMP. They are formaldehyde, located at Building 48 (B-48), in the eastern end of KP, and vinylidene chloride , located at Building 119 (B-119) in the middle section of KP. Both of these locations are situated in the City of Rochester. Vinylidene Chloride Storage Tank - Kodak Park Building 119 The vinylidene chloride storage and delivery system was installed in May, 1994. It is located at B-119 and operated by Kodaks World Wide Synthetic Chemicals Division - Rochester (WW-SCD). B-119 manufactures specialty polymers and organic chemicals via batch processes for the photographic film and paper business. Vinylidene chloride is received at the B-119 courtyard unloading station in tank trailers containing 4000 gallons per delivery. Three to four deliveries are received annually. The courtyard is surrounded on the east, west, and south by B-119. The unloading station is a concrete pad sloped to a drain which is connected to a 9200 gallon underground tank designed to capture more than the entire contents of the tank trailer delivery in the event of a spill or release. The unloading station is equipped with a sprinkler system and alarm activation buttons for use in the event of an emergency. The alarm system was upgraded in 1998. The vinylidene chloride is delivered to and stored in a 6,700 gallon double walled stainless steel underground storage tank which is surrounded by a containment tank equipped with a vapor detector. The vinylidene chloride is unloaded to the tank by gravity via pressure-rated hoses. The unloading system involved a closed system where the displaced gasses from the storage tank are returned to the trailer. The tank is equipped with a pressure relief valve set at 35 psi and a rupture disk set at 30 psi. The process is a manual operation with operator attendance mandatory during the entire unloading. The systems status is monitored by a computer control system located in a small shed adjacent to the unloading station. Worst Case Scenario The worst case scenario could occur if the tank trailer fails during unloading and the entire 4000 gallo ns spills onto the concrete pad. 2200 gallons would be contained on the pad and 1800 gallons would spill over forming a pool 1 cm deep. 16,200 lbs would vaporize over a 10 minute period leading to a vapor cloud explosion of 10% of the vaporized material. The 1 lb. overpressurization radius for this incident would be approximately 625 feet. The off-site impact would only be to the north and would encompass a section along Ridge Road commercial businesses. The endpoint would not reach any residential populations for this scenario. Alternate Release Scenario The alternate release scenario would occur if the unloading hose ruptures and the valve is manually closed by the system operator (required to be in attendance during the unloading operation) after a 1 minute release. At a 50 gallon per minute flow rate this would result in 50 gallons or 503 pounds released. A pool fire could result with the endpoint for a radiant heat level of 5 kw/m2 for 40 seconds being less than 25 feet. There would be no off-site consequences for this scenario. Formaldehyde Storage Tank - Kodak Park Building 48 The formaldehyde storage and delivery systems were upgraded in 1991. The systems are located in the Building 48 (B-48) Center Tank Farm and operated by Kodaks World Wide Photochemicals Manufacturing - Rochester (WW-PCM), where a variety of dry powder and aqueous solution mixtures are manufactured for the processing of photographic film and paper. Formaldehyde is actually a component of Formalin (37% formaldehyde solution with water and methanol). Formaldehyde is unloaded from tank trailers at B-48 via a dedicated pump and piping system to the storage tank. Formaldehyde is then delivered from the storage tank to batch chemical mixing tanks via a dedicated transfer pump, piping, and distribution system. The unloading and transfer systems are operated and monitored with a computerized control system which requires that a trained operator be in attendance and provide system input throughout the process. Quantities of formaldehyde delivered to B-48 range from 4,500 to 5,000 gallons (approximately 6 deliveries are made per year). Capacity of the storage tank is 10,000 gallons. Individual batch operations involving formaldehyde in photochemical formulations range from 200 to 6,000 gallons. The unloading station is comprised of a diked concrete pad which is sloped to a drain. The drain is connected to an 18,000 gallon underground tank designed to capture more than the entire contents of the tank trailer delivery in the event of a spill or release. During unloading, displaced storage tank vapors are transferred back to the tank trailer. The unload station is equipped with an automated sprinkler system and manual alarm indicators which can be activated by the operator in the event of an emergency. The storage tank is located in an enclosed shed which is also equipped with a trench drain connected to the underground tank. The storage tank is equipped w ith level indicators, a conservation vent, and a rupture disk. The storage tank and associated piping are all constructed of stainless steel. Worst Case Scenario The worst case scenario could occur if the unload arm-tank trailer connection fails during delivery to the storage tank releasing the entire contents of the tank trailer. The formaldehyde could then vaporize while the diked concrete pad confines the release pool and the trench drains divert the release to the underground tank. The endpoint determination of 0.012 milligram/liter is less than 500 feet, resulting in no off-site consequences. Alternate Release Scenario The alternative scenario could occur if exterior piping ruptures during an unloading operation releasing approximately 45 gallons per minute for 10 minutes resulting in a total release of 450 gallons (as formalin 37%) before the operator would implement emergency shutdown practices. A partially diked section of paved asphalt, bordered by building structures, limits the pooling and the trench drains would divert the release to the underground tank. The endpoint determination of 0.012 milligram/liter is less than 400 feet, resulting in no off-site consequences. General Accidental Release Prevention Program Both of these storage and delivery systems are also covered under the Occupational Safety & Health Administration (OSHA) 1910.119 Process Safety Management regulation and are in compliance with all elements of that regulation. Process Hazard Analyses (PHAs) have been conducted to determine potential hazards and many safeguards are in place to prevent the occurrence of a catastrophic release. The systems are also covered by the New York State Chemical Bulk Storage regulations. Required design standards, daily, monthly and annual inspections and continuous leak detection are only a few of the requirements that are followed to be in compliance with this regulation. The delivery of raw materials has been identified in both the Worst Ca se Scenarios and Alternate or More Likely To Occur WCS. Because of the infrequency of these deliveries (3-4 times annually for vinylidene chloride and 6 times annually for formaldehyde) the risk of a release has been lowered. Additionally, formaldehyde usage at the site, according to Emergency Planning and Community Right To Know Act of 1986 data, has been reduced by approximately 58%. The tanks have been engineered to strict American Society of Mechanical Engineers (ASME) codes. The vinylidene chloride tank and operation adheres to our suppliers (Dow Chemical) Monomer Safe Handling Guides. An inhibitor is added and a nitrogen blanket is always present to prevent unwanted polymerization. A rigorous training program is in place to insure the employees are well trained in the handling of these materials and operation of the equipment. The vinylidene chloride program follows the American Training System methodology while the formaldehyde program follows the Analytical Methods Training System (AMTS) protocols. In addition to the operational training received, emergency training is also provided. All employees are trained to report spills or leaks to supervision and to call 911 for emergency assistance from the Kodak Fire Department (KFD). Immediate response is provided by the KFD including a trained HAZMAT team. Reviews are attended and conducted by management and operations personnel to determine the root cause of incidents and corrective actions necessary to prevent a recurrence. Detailed operating procedures are written and followed to insure correct handling of these materials and proper operation of the equipment. Regular Health, Safety and Environment (HSE) Reviews of procedures are conducted and updates are made in the case of any equipment or procedural changes. Operators are trained to carefully follow the written procedures. A strict Management of Change process is in place to prevent any unapproved changes from being made. All equipment c hanges are brought to a committee for design, HSE and management review prior to implementation. Both the HSE Review and Management of Change processes are implemented by departmental policies. Equipment maintenance is an essential component of the facilitys Mechanical Integrity Program. In the WW-SCD, a computer-based system maintained by the Maintenance and Engineering Department, contains the maintenance procedures and the regular Preventative Maintenance (PM) program and is the backbone of the Mechanical Integrity Program. These procedures are carried out by trained mechanics. The procedures are regularly reviewed and approved by departmental management and HSE personnel to insure they are up to date and accurate. In the WW-PCM area, the Mechanical Integrity Program is aligned with American Petroleum Institute (API) codes. In both areas a hot work permit process is in place as well as other safe work practices such as lockout/tagout and confined space entry procedures. E mergency Response Program The Kodak Park site of the Eastman Kodak Company maintains a full time paid professional Fire Department. The Fire Department maintains at least 7 major pieces of mobile fire suppression and support apparatus and currently has a staff of approximately 80 personnel. The Fire Department responds to all fires, explosions, major gas or chemical leaks and all other life threatening situations at the Kodak Park site. The Fire Department provides fire suppression/emergency response capability in addition to maintaining related fire fighting equipment and performing supervisory checks of fire protection systems (valves, high points, etc.). It also performs inspection/testing functions, along with development, administration and implementation of departmental training. Departmental training is conducted at least once each month on various topics such as the use of SCBA, selection and use of appropriate personal protective equipment, selection and use of special e quipment, building familiarization tours to acquaint firefighters with processes and hazards inherent to various areas of the site, hazard communication, radiation safety, and other similar/related topics. Fire fighting equipment at each fire house receives a daily check for operational readiness. A more in-depth inspection of equipment is conducted on a weekly basis. Five Year Accident History There have been no incidents within the last five years for either process described above. Planned Changes to Improve Safety There are no planned changes at this time. Potential changes that are identified during HSE Reviews or PHAs are implemented when they are shown to provide significant improvements to worker or community safety. |