Solutia Trenton Plant - Executive Summary |
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1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At the Solutia Inc. Trenton site, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. The plant's accidental release prevention program is built upon a comprehensive safety program. This includes a variety of procedures, equipment and training. These program components are designed to effectively prevent, mitigate and respond to potential release situations. Routine inspection and preventative maintenance programs are used to ensure integrity of hazardous material storage tanks and key safety controls. Process equipment changes are reviewed during design phase for potential environmental, safety or health impacts. Rout ine audits and inspections are performed to ensure correct procedures are followed. Alarms, interlocks, spill containment, vapor suppression, vent vapor collection and treatment systems are in place for control and mitigation of ammonia and vinyl acetate releases. Any release incident is investigated to identify prevention and improvement opportunities. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of planned improvements at the faciltiy to help prevent accidental chemical releases from occurring and adversely afecting our employees, the public, and the environment * The certification that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program 2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES Our Trenton facility produces Saflex plastic interlayer, Polyvinylbutyral speciality resins and commercial Phosphates using a variety of chemicals and processing operations. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics Ammonia - 107,000 lbs stored onsite for use in the production of ammonium phosphate salt poducts which are used in the fertilizer and fire fighting industries. Vinyl acetate monomer - 719,000 lbs stored onsite for use in polymerization reactors to manufacture speciality polyvinylbutryal polymers used for Safety Glass manufactu re onsite and sold for speciality applications such as retro-reflective traffic safety signs and photographic applications. Vinyl acetate monomer on rail spur - From 0 to 8 railcars (containing a maximum of 105 tons each) depending on railroad shipments stored offsite on leased tracks for use in the polyvinylbutryal process mentioned in the previous paragraph. Our accidental release prevention programs and our contingency planning efforts help us effectively mange the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. 3.0 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemicals Per EPA gui dance, the worst case scenario for the Solutia Trenton Plant is catastrophic failure of the largest vinyl acetate monomer (VA) railroad tankcar used. 210,330 pounds of VA are assumed to be released onto flat pavement, forming an instantaneous pool one centimeter deep. No credit is taken for the preventive measures currently in place to avoid or reduce this type of incident. The VA vapor is assumed to move downwind under the worst possible weather conditions using RMP Comp version 1.01 to determine the ERPG-2 endpoint. Worst-case Release Scenario - Regulated Flammable Chemicals There are no flammables at this site for which the regulatory requirements of the RMP program are triggered. Alternative Release Scenarios - Regulated Toxic Chemicals For ammonia, the alternate release scenario is breakoff of a bottom nozzle on the storage tank. The entire contents, 107,000 pounds, is assumed to be released into the dike and begins to vaporize. No credit is taken for preventive measures, such as vapor detectors, currently in place. Results were calculated using PHAST version 5.2 modeling software. For vinyl acetate (VA), one alternate release scenario is a bottom weld failure of the storage tank. The entire contents, 73,800 pounds of VA, is assumed to be released into the containment dike and begins to vaporize. No credit is taken for other preventive measures, such as vapor detectors, currently in place. Results were calculated using PHAST version 5.2 modeling software. Another vinyl acetate (VA) alternate release scenario is a bottom nozzle leak on a tank car on the railroad siding. 37,700 pounds of VA is assumed to leak onto the ground and to evaporate for 30 minutes before the spill is covered with emergency foam blanket. No credit is taken for terrain pooling effects. Results were calculated using PHAST version 5.2 modeling software. We are using this modeling information to help us ensure that our emergency response plan and the community emergency respon se plan address all reasonable contingency cases. 4.0 GENERAL ACCIDENT RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We maintain a number of programs to help prevent accidental releases and ensure safe operation. The accident prevention programs in place for both ammonia and vinyl acetate include: a management of change program, a detailed process hazard analysis or revalidation every five years, internal PSM audits, training programs which provide for both new hire and refresher training for personnel assigned to the areas, detailed operating procedures, a contractor management process, pre-startup safety reviews, a hot work permit system, and mechanical integrity programs that provide for periodic inspection of critical equipment and the quality assurance of spare parts. Ammonia The ammonia bearing processes in the Solutia Trenton Phosphates operation are in compliance with the OSHA PSM standard. The ammonia containing processes also adhere to inte rnal corporate-wide "Ammonia Handling Guidelines". The guidelines were established to ensure that anhydrous ammonia is handled consistently across all Solutia sites. Recent capital investment in the ammonia areas which have substantially improved the safety of the process and lowered the risk of accidental release include the following: Upgrading of the ammonia storage area. Highlights include a brand new storage tank, replacing a circa 1929 vessel with a modern storage vessel with improved metallurgy and welding techniques. Threaded piping and cast iron valves were replaced with welded steel pipe and valves. Sight glasses were removed and replaced with automatic level detection. A remote emergency shutdown system was installed. Replacement of the control system in the ammonia salt processing area with a modern distributed control, computerized system. Addition of controls and an automatic 3-way valve that would switch over to a redundant relief valve on the ammonia storage tank should a relief valve open. This was installed to protect against cases where a relief valve faults open when it should not (tank pressure is not at designed relieving pressure). This will prevent the unnecessary venting of the storage tank that has a pressure within tolerance. Vinyl Acetate The polyvinylbutryal process is in compliance with the OSHA PSM rule. Vinyl acetate storage and use was audited in 1994 under the Process Safety management system and all vessels containing vinyl acetate have been upgraded during the years as recommended in the audit. New systems added to improve safety and prevent release as a result of the audit are: Vapor detectors in two sump locations to detect spills, reinforcement of the three polymerization reactors to withstand deflagration without releasing vessel contents, replacement of two collector tanks and a day storage tank with new tanks rated to withstand deflagration without releasing contents, and nitrogen inerting of the main viny l acetate storage tank with an oxygen analyzer to prevent a deflagration. Rail car sittings were fitted with track pans that direct any potential spill to a containment sump. The vent chiller system has been upgraded and replaced for the storage tanks, and a new chilled water coil was added to the collector tank design to reduce emissions and improve safety. In addition, vinyl acetate distillation for the removal of polymerization inhibiter has been eliminated, and a new safer process which directly reacts the vinyl acetate as shipped has reduced the emissions from the process and improved process safety. The vinyl acetate handling area was reaudited in May, 1999, as part of ongoing compliance with OSHA PSM and additional recommendations for improvement were identified as part of that effort. Vinyl acetate shipments into the plant are treated at the supplier with inhibiter to prevent polymerization reaction while in shipment and storage. All vinyl acetate rail cars that enter the plant for unloadinig are sampled for identification and quality to prevent the accidental mixing of a different substance that could react in the storage tanks. The storage tanks and reactors have chilled vent condensers to reduce emissions. In addition, the reactors have vapor scrubbers to further reduce any vinyl acetate emissions. The reactors and collector tanks are equipped with back up cooling water and with automatic short stop systems that in an emergency can stop the reaction. These individual elements of our prevention program work together to prevent accidental releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5.0 FIVE-YEAR ACCIDENT HISTORY We keep records for all accidental chemical releases that occur at our facility. The Trenton plant's release records ha ve been reviewed for the period 1993 - May, 1999. This review identified no releases from covered processes that resulted in deaths, injuries, or significant property damage on-site, or off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 6.0 EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting the workers, the public, and the environment during emergency situations. The Solutia Trenton plant maintains an on-site emergency response team in order to ensure that releases, if they should occur, are handled in a timely and effective manner. This team attends monthly training sessions in order to continually practice and increase the team's response effectiveness. Annual drills are conducted with local fire and pol ice departments and the Downriver Emergency Response Team so that efforts to respond to a release are conducted in a coodinated and organized manner. Furthermore, we coordinate our plan with the Wayne County Local Emergency Planning committee (LEPC) and have around the clock communications capability with appropriate LEPC officials and emergency response organizations. This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick and effective response to an incident. 7.0 PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: Ammonia The most recent Process Hazard Analysis (PHA) performed for the anhydrous ammonia processes, completed in March, 1998, generated 47 action items. These action items will help improve our ability to prevent and/or better respond to accidental anhydrous ammonia releases . The improvement items are a cross section of procedural/managerial and technological improvements. Vinyl Acetate The most recent Process Hazard Analysis (PHA) performed for the process that encompasses vinyl acetate use and vinyl acetate railcars, completed in May, 1999, generated 14 action items, 6 of which are related to vinyl acetate. These action items will help improve our ability to prevent and/or better respond to accidental vinyl acetate releases. The improvement items are a cross section of procedural/managerial and technological improvements. |