Neste Resins Corporation - Andalusia, AL - Executive Summary |
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Risk Management Plan Executive Summary The Risk Management Program at Neste Resins, Andalusia, Alabama facility, incorporates a Risk Management Plan that assimilates the following elements: Accidental Release Prevention and Emergency Response Policy Neste is committed to a clean, safe and healthy environment through the implementation of a formal management system dedicated to the prevention of pollution and continual improvement of our environmental, health and safety performance. We are committed to comply with applicable governmental laws and regulations and to meet the requirements of other organizations to which we subscribe. Our employees are our most important asset, and an integral part of the success of our environmental, helath and safety programs. We will properly train, equip and direct employees to perform their jobs in a safe and environmentally responsible manner. We review our performance against our objectives and targets and update the Environmental Managemen t System as appropriate. This policy shall be communicated to all employees and made available to the public. Facility Information The primary activities at Neste Resins are the manufacture of formaldehyde and the production of specialty resins. Formaldehyde is produced from the processing of methanol. Anhydrous ammonia is used in the production of proprietary resins. The maximum quantity of formaldehyde in storage in one vessel is 49,000 gallons at a concentration of 53% by weight. The maximum quantity of stored anhydrous ammonia is 52,000 lbs, stored in one tank. Worst Case and Alternative Case Scenarios The worst case accidental release scenario would be the total release of the anhydrous ammonia storage tank over a 10-minute period. The maximum quantity released would be 52,000 lbs which represents the administrative limit imposed by the facility. The potential distance to the toxic endpoint (point of dispersion to 200 ppm) is 2.2 miles. The alternative release scenario for anhydrous ammonia is the rupture of the transfer hose during filling of the on-site tank. The quantity released would be 28 lbs. The potential distance to the toxic endpoint (point of dispersion to 200 ppm) is 0.05 miles. The alternative release scenario for formaldehyde would be the release of 22,000 lbs of formaldehyde solution at a concentration of 53% by weight formaldehyde due to tank overfilling. The potential distance to the endpoint (point of dispersion to 0.012 mg/l) is 1.2 miles. Accidental Release Prevention Program All covered processes at Neste Resins are in Program 3 and meet the requirements of the OSHA Process Safety Management (PSM) program. The existing OSHA PSM-required accidental release prevention program meets nearly all RMP requirements. Where the programs differ, the Neste Resins' program elements have been modified to incorporate RMP issues. An example would be that the compliance audit procedures required as part of Neste's PSM program have been mo dified to include evaluations of the RMP implementation. Another example would be that pre-startup review procedures have been modified to incorporate reevaluation of the facility accident scenarios to determine whether the worst case and alternate case scenarios for releases are still consistent with the design and operation of the process being started. Five Year Accident History Neste Resins has had no accidental releases of anhydrous ammonia or formaldehyde in the last five years that have caused any deaths, injuries, or significant property damage at the facility nor have there been any accidents which led to off-site deaths, injuries, evacuations, sheltering in place, property or environmental damage. Emergency Response Program Neste Resins has established a facility emergency response plan that meets the requirements of both the OSHA PSM program and the EPA RMP program. This response plan describes the procedures for informing the public and local emergency response agencies of a release, provides documentation of proper first-aid and emergency medical treatment for accidental exposures, and procedures and measures for emergency response after a release. Local emergency response and medical treatment personnel have worked with Neste to provide for the safe control and treatment of releases of formaldehyde and anhydrous ammonia. Neste employees receive mandatory training on emergency response procedures and emergency response equipment use, inspection, testing, and maintenance. Emergency response procedures are reevaluated as part of the management of change and pre-startup review requirements of the PSM and RMP programs. |