Akron Polymer Plant - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Akron Polymer Plant are strongly committed to associate, 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 associate training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with Akron Fire Department which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Production of S BR Paint, Toner and Reinforcing Resins. The one regulated substances at our facility, 1,3-Butadiene is used as a raw material for the preparation of these SBR resins. The maximum inventory of 1,3-Butadiene at our facility is 120,000 lbs. 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. Methodology given in the RMP Offsite Consequence Analysis Guidance by the EPA and the on-line EPA program RMP COMP have been employed by our facility to perform worst and alternative case release scenarios. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from a Butadiene Storage Tank - in the Tank Farm process. The scenario involves the release of 120,000 lbs. of 1,3-Butadiene. Passive mitigation systems such as dikes have been considered when evaluating this scenario. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of 0.39 miles is obtained corresponding to an endpoint of 1 psi overpressure. One alternative release scenario submitted for Program 3 flammable substances involves a release from a Butadiene Storage Tank - in the Tank Farm. The release is assumed to result in a vapor cloud explosion. The scenario involves the release of 30,240 lbs. of Butadiene in 60 minutes. Passive mitigation controls such as dikes are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the endpoint of 1 psi overpressure is 0.11 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition). A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. The following sections briefly describe the elements of our release prevention program that are in place at our stationary source. Process Safety Information Akron Polymer Plant maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts 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. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are reval idated at a regular interval of every five years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Akron Polymer Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved with the processes. Training Akron Polymer Plant has a comprehensive training program in place to ensure that associates that are operating processes are completely competent in the operating procedures associated with these processes. New associates receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is pro vided at least every 3 years, whenever there is a change in the process, or as required. Mechanical Integrity Akron Polymer Plant carries out highly documented maintenance checks on process equipment to ensure proper functions. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Akron Polymer Plant to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other associate 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-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Akron Polymer Plant. 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 Audits Akron Polymer Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Akron Polymer Plant promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situatio n 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. Assocaite Participation Akron Polymer Plant truly believes that process safety management and accident prevention is a team effort. Company associates are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our associates have access to all information created as part of the facility's implementation to the RMP rule in particular information resulting from process hazard analyses. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Akron Polymer Plant has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contract ors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Akron Polymer Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Akron Polymer Plant carries 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 and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a m odified emergency response. Summit County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety There are currently no planned activites at this time. |