National Starch and Chemical Company - Executive Summary |
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EXECUTIVE SUMMARY 1. Accidental Release Prevention and Emergency Response Policies We at National Starch and Chemical are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled The National starch Meredosia facility manufactures various adhesives and polymer resins. The site began operations in 1955 and currently employs about 282 people. The facility is comprised of many batch process systems that manufacture water based adhesives, solvent based adhesives, hair spray resin and other polymer resins. Our products are used in various industries e.g. paper manufacture r, packaging industries, hair care industries, personal hygiene products to name a few. Following chemicals are included in our Risk Management Plan: Chemicals RMP Category Inventory Vinyl Acetate Toxic Substance 300,000 gallon Acrylonitrile Toxic Substance 16,000 gallon Ethylene Flammable Substance 50,000 gallon 3. The Worst Case Release Scenario(S) And The Alternative Release Scenario(S), Including Administrative Controls And Mitigation Measures To Limit The Distances For Each Reported Scenario The worst-case scenario for vinyl acetate includes catastrophic failure of storage tank releasing entire content of the storage tank into the containment area. The distance to end point is 1.03 miles. The effected distance extends beyond our property boundaries and it includes a small number of residential dwellings (43 persons). The alternate release scenario for vinyl acetate includes pipe breaking between storage tank and reactor system. The distance to end point is 0.20 miles , which marginally extends beyond our property boundary. No affected residential population has been identified. The alternate release scenario for acrylonitrile includes overfilling of storage tank. The distance to end point is 0.22 miles, which marginally extends beyond our property boundary. No affected residential population has been identified. The worst-case scenario for ethylene includes vapor cloud explosion following a release of the entire contents of the cryogenic ethylene storage tank. The distance to end point is 0.33 miles , which is within the company boundary. No affected population has been identified. The alternate release scenario for ethylene includes a jet fire from a hole in the ethylene storage tank. The distance to end point is 560 feet, which is within the company boundary. No affected population has been identified. 4. The General Accidental Release pre vention Program and the Chemical Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accident release prevention requirements set out under 40 CFR part 68 of the EPA guidelines. The following section briefly describes the elements of the release prevention program that is in place at our stationary source. Process Safety information We maintain a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis We conduct comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is HAZOP and /or What If analysis whichever appropriate. A team has performed all the process hazard analysis (PHA) with expertise in engineering, and process operations. All the PHAs are updated and revalidated by a competent team described above and all action items/ recommendations are resolved in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, we maintain written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, and normal shutdown . We have a system in place so that all the required operating procedures stay current and accurate. It is readily accessible to operators involved in the processes. Training We have a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. We have a system in place so that all required training are conducted in a timely manner as required by law. Management of Change Written procedures are in place to manage changes in process chemicals, technology, equipment and procedures. Pr ocess operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-startup safety reviews related to new processes and to modifications in established processes are conducted as a regular practice. 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 Audit We conduct audit on a regular basis to determine whether provisions set out under the PSM and RMP rule are being implemented. These audits are carried out atleast every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation We investigate any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substanc e. These investigations are undertaken to identify 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 We believe that accident prevention through implementation of PSM/RMP is a team effort. Company employees routinely participate in process hazard analysis study, operating procedures update, department inspection, accident investigations, updating safe work permit procedure, emergency drills etc. Contractors On occasion, we hire contractors to conduct specialized maintenance and construction activities. Prior to selection of a contractor, a through evaluation of safety performance of the contractor is carried out. We have a strict policy of informing the contractors of known potential hazards related to contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. The following sections briefly describe the chemical specific prevention steps. We have constructed vinyl acetate and acrylonitrile storage tanks applying safe engineering practices. we conduct mechanical integrity testing of the tanks on a regular basis. The tanks have secondary containment and hydrant mounted monitors to minimize the impact in case of a release. The ethylene storage system was built in 1997 as per all applicable engineering standard. The access to the tank is restricted. It has been pressure tested prior to placing in service and we conduct mechanical integrity testing of the tank on a regular basis. All electrical accessories such as pump, instruments and wiring is explosion proof and constructed as per applicable electrical codes. It has a state of the art redundant pressure relief system and is monitored 24 hours a day by a remotely located video camera. The loading of the product is conducted during daytime only and any excess emission of ethylene is passed through a flare system. 5. Five- Year Accident History We have had an excellent record of preventing accident releases over the last 5 years. There has been no accidental release during this period. We have had some process upsets but none that are reportable under this program or have had any off site impact. 6. Emergency response Plan We have 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 medical treatment, evacuations, notification of local emergency response agencies. To ensure proper functioning for potential chemical accidents, we communicate and work closely with Local Emergency Planning Committee (LEPC) and other community responders, such as fire department, ambulance crews, etc. These responders and National employees perform emergency drills together periodically. The emergency response plan is updated promptly to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release program. Following are some of the major steps we are planning to take to improve safety at our facility. * upgrading our ethylene fire protection system. The project is expected to be completed by second quarter, 2000. * Contributing towards the purchase of an emergency alarm system for the Meredosia community. We have contributed 20 percent of the cost and the project is scheduled to be completed by third quarter, 1999. |