BFGoodrich Performance Materials Taylors Plant - Executive Summary |
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THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED The BFGoodrich Performance Materials Plant in Taylors, South Carolina is a specialty chemical manufacturing plant located six miles northeast of Greenville, South Carolina on a 21-acre tract surrounded by light industry and residences. We manufacture chemical products used by the textile industry for finishing fabrics. Our products are used by the textile industry to improve the characteristics of woven and knitted fabrics. This includes the resin that makes fabrics wrinkle free for the consumer. We have 74 employees with an annual payroll of $5.7 million, paying about $700,000 in local taxes annually. Each year we buy about a million dollars of goods and services, and pay about $800,000 for utilities. Our plant uses certain chemicals as raw materials, one of which brings us under the EPA Risk Management Rule: a water solution of formaldehyde which is used to produce permanent press resin. The types of programs recently req uired by the RMP to prevent serious accidents have been in place for several years at this plant, since before its acquisition by BFGoodrich in December 1997. We have long understood the relationship between good safety and good business, as reflected by our numerous safety awards, including 1998 South Carolina Manufacturer's Alliance State Safety Award. THE ACCIDENTAL RELEASE PREVENTION PROGRAM AND EMERGENCY RESPONSE POLICIES AT THE STATIONARY SOURCE It is the policy of the BFGoodrich Taylors Plant to meet or exceed the requirements established by applicable safety, health and environmental regulations promulgated by Federal and State agencies. BFGoodrich safety policies and practices have historically preceded the regulation of such practices under, for example, the OSHA Process Safety Management Standard and EPA Risk Program Management Rule. Our policy is to maintain at a practical minimum the potential for harm to on-site employees and contractors, the public, and the environme nt, and to have in place contingency plans, coordinated with local responding agencies, for the unlikely event of a serious accidental chemical release. Since acquisition by BFGoodrich, the Taylors facility is committing even greater resources to consolidating our strong safety performance. A related program in which we are participating is a company-wide Y2K effort to ensure that Y2K issues associated with our computer-based systems and those of our suppliers will not adversely impact our strong safety performance. We are also a Responsible Care(r) company under the Chemical Manufacturer's Association program, and a member of the Safety Committee of the South Carolina Manufacturer's Alliance. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The BFGoodrich Taylors plant has in place a thorough, ongoing program of process safety management (PSM). This program calls for implementation and maintenance of procedural and engineered safeguards a t the plant to minimize the likelihood of a significant release of a hazardous chemical, and to eliminate or reduce the effects of any release that might occur. We have invested and continue to invest substantial effort and capital in maintaining our strong safety and environmental performance. Some examples of our investments include: - Increasing the height of the concrete walls that surround tanks containing hazardous chemicals, at a cost of $20,000 - Coating the internal surfaces of concrete containment areas to protect the ground against spills, at a cost of $30,000 - Upgrading the formaldehyde solution storage tank to stainless steel to decrease the chance of leakage, at a cost of $17,000 - Installation of catwalks and safety ladders to improve worker safety, at a cost of $28,000. Some highlights of our program include: (1) Process Hazard Analysis -We routinely perform and maintain up to date, systematic and thorough studies of our operations to identify what could go wrong , identify means of eliminating or reducing design or procedural weaknesses, and implementing improvements. (2) Process design - Our processes and equipment are designed for safety in accordance with applicable industry standards and best engineering practices. Designs include, as appropriate, emergency shutdown systems, pressure relief devices, ventilation systems, and release sensoring systems. Our storage vessels which contain the largest quantities of hazardous chemicals are contained in concrete dikes. (3) Training - Our operating and maintenance personnel are trained thoroughly on their job tasks, on safe work practices as they relate to their jobs, and emergency contingency actions, before they may operate or maintain equipment. They also receive refresher training periodically. Our procedures for operating or maintaining processes, general safe work practices, and emergency response, are fully documented and maintained up to date with any changes at the plant. (4) Mainte nance - Each item of equipment at the plant that is involved in maintaining safety or in responding to an abnormal situation is inspected, tested and/or maintained on a frequency that reflects its service and condition. (5) Management of Change - no change to equipment or procedure can take place at the plant without a thorough review of the implications of that change to plant safety. No change may adversely impact the safety built into the design of our processes and equipment. Our PSM Program is tuned to address the specific hazards of the chemicals we use. For example; our operating, maintenance, safe work, and emergency procedures address personal protective equipment appropriate to the chemical being handled. THE FIVE-YEAR ACCIDENT HISTORY We have had no events at the BFGoodrich Taylors Plant that would qualify for inclusion in the RMP 5-year accident history. In fact, this plant has never had a spill of formaldehyde significant enough to be reportable in the more than f orty-year history of the plant. THE EMERGENCY RESPONSE PROGRAM We have in place a written emergency response plan that we coordinate with the Taylors Fire Department and Greenville County Emergency Planning authorities. New personnel are trained in the plan, we conduct refresher training annually, and we retrain in the event of changes in the plant. The plan is in compliance with RMP regulations, as well as applicable EPA and OSHA requirements. PLANNED CHANGES TO IMPROVE SAFETY Our safety program, run by BFGoodrich safety and environmental professionals, is ongoing, involving the identification and implementation of numerous means of incremental safety performance. THE WORST-CASE RELEASE SCENARIOS AND THE ALTERNATIVE RELEASE SCENARIOS The RMP provides a detailed prescription for what should be considered a worst case scenario (WCS). Under that prescription we have identified a WCS. It involves the spontaneous, catastrophic failure of a vessel used to store formaldehyde solution . Based on use of the EPA Offsite Consequence Analysis Guidance, this scenario is calculated to have offsite impact extending two tenths of a mile from the vessel. A more credible scenario (although still highly pessimistic), called the alternative release scenario (ARS), was also analyzed. As required by the RMP Rule, we chose a hypothetical ARS that is severe enough to have effect beyond our fenceline. Our selected ARS is a highly unlikely scenario of the type our process safety management program protects against. In our hypothetical ARS, the operator is pumping formaldehyde solution from a delivery tanker into the storage vessel when the flexible hose through which the liquid is transferred breaks loose because of a poor connection. This results in a liquid spill to the ground. The operator, who is required to be present during unloading, is pessimistically assumed to take several minutes to turn off the transfer pump. The spilled liquid begins to evaporate resulting in the dispe rsion of formaldehyde vapor. The release is calculated (using the EPA Guidance method) to have impact beyond our fenceline, extending two tenths of a mile from the vessel, which is up to 300 yards beyond our fenceline. There are several safeguards that protect against this scenario occurring. First, our procedures require that the hose connections be thoroughly checked before the hose is used to transfer liquid. Second, we pressure test each flexible hose before it is used to transfer a hazardous material. Any leaks or poor connections would be detected during the pressure test. Third, because our operating procedures require an operator to be present during unloading, the operator would in reality turn off the transfer pump within seconds, not minutes, of a spill occurring. We expect scenarios such as this ARS to continue to be highly hypothetical and unlikely due to our ongoing program of process safety. We take pride in our safety programs and our frequently awarded safety perform ance. |