Lord Corporation - Saegertown Operations - Executive Summary |
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EXECUTIVE SUMMARY 1. Accidental release prevention and emergency response policies. Lord Corporation operates a Chemical Products Division manufacturing facility in Saegertown, PA. By policy, Lord Corporation is committed "to operate our plants and facilities in a manner that protects the environment and the safety and health of our employees and the public". In pursuit of our corporate policy, the Saegertown manufacturing facility has evaluated every Risk Management Planning listed chemical onsite and developed individualized risk reduction plans as follows: 7 Bromine - improved passive mitigation to prevent offsite consequences. 7 Chlorine - reduced onsite storage below threshold quantity so that only general duty compliance is required. 7 Toluene Diisocyanate - converted from bulk storage tank to drum storage so that no reasonable release scenario exceeds threshold quantity so that only general duty compliance is required. 7 Hydrochloric Acid - all uses from purchase thr ough disposal do not exceed the compliance concentration of 37 percent. Our commitment to protect our employees and the public from accidental releases includes safety reviews, alarms, emergency training, active mitigation, and passive mitigation. Both plant and corporate emergency teams are available to respond to an emergency release. Equipment available to team members includes pagers, cell phones and laptop computers. Personal protective equipment available includes chemical resistant suits and supplied air respirators. Access to the site is restricted (24 hour site security/guard service) to authorized facility employees, management personnel, and contractors. Bromine is the only substance handled at this facility that exceeds the threshold quantities of covered substances regulated by EPA's risk management program (RMP) rule. The maximum amount of bromine that can be stored at this facility is 52,000 lbs. (26,000 pounds in each of two bulk storage tanks). The Saege rtown facility handles bromine, which is considered hazardous by EPA. The same properties that make bromine valuable as a reactant at our facility also make it necessary to observe certain safety precautions in handling bromine to prevent human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable federal and state rules and regulations. Safety depends upon the manner in which we handle bromine combined with (1) the safety devices inherent in the design of this facility, (2) the safe handling procedures that we use, and (3) the training of our personnel. Our emergency response program is based upon the requirements in OSHA's Employee Emergency Plans (29 CFR 1910.38) and Hazardous Waste and Emergency Operations (HAZWOPER) regulation (29 CFR 1910.120). The emergency response plan includes procedures for notification of the local emergency responde rs, County and State agencies and notification of any potentially affected neighbors. An up-to date Off-Site Emergency Response Plan for Lord Corporation - Saegertown, PA Operations is maintained with the Crawford County Office of Emergency Management (OEM) Director and is an integral part of the Environmental Emergency Response Plans for the Lord Saegertown Operations (which is also maintained by the Crawford county OEM, PADEP-Meadville Office, and the Saegertown Volunteer Fire Department). Copies of the Bromine Emergency Response Plan for Lord Corporation have also been distributed and reviewed with the Crawford County HAZMAT team and Saegertown VFD. The Emergency Response Plans have been reviewed and coordinated with the Crawford County OEM, Crawford County Hazardous Materials Team (HAZMAT), and the Saegertown VFD. The above agencies tour our facility periodically and are familiar with our operations. The Crawford County OEM has coordinated the Lord Emergency Response P lan with the Community Emergency Response Plan (CERP) and has been directed by the Crawford County Local Emergency Planning Committee (LEPC) to exercise the CERP annually. 2. The stationary source and regulated substances handled. Lord Chemical Products Division (hereafter called Lord CPD) in Saegertown is an operating unit of the Lord Corporation headquartered in Cary, North Carolina. Lord CPD produces chemical specialties commercially defined as adhesives and coatings, plus several rubber chemicals. The products we manufacture are essentially mixtures comprised of solvents, water, chemical intermediates, and other chemical materials. These products are used by heavy industry to bond rubber elastomers to metal supports and frames to produce automobile engine mounts, transmission seals, energy absorbing bumper subassemblies and other applications including shock and vibration control uses. We also manufacture industrial adhesives which are used by industry in the manufa cture of laminated roll goods and structural adhesives for many manufacturing oriented applications. Additionally, Lord CPD manufactures a line of urethane coatings which provide corrosion resistant painted surfaces for heavy industrial use, as well as coatings for vinyl sheet and tile flooring applications found in the home or in institutions. Bromine is one of the reactants required to manufacture two intermediate products which are eventually blended with other materials to produce several of our products. The processes covered by this RMP include Brominated Intermediate #1 Manufacturing and Brominated Intermediate #2 Manufacturing. Brominated Intermediate #1 and #2 Manufacturing Processes The Saegertown plant has handled bromine safely for more than 25 years. A detailed Process Hazards Analysis (PHA), covering all known equipment and processes associated with bromine handling, was initially conducted in 1992. The PHA programs for these processes are reviewed every th ree years and the management of these processes is on-going. The processes use glass lined steel reactor vessels which are jacketed to enable cooling and heating via circulated jacket water. The jacket water is either heated by steam or cooled by city water through a heat exchanger. Bromine is delivered to Lord in a special tank truck consisting of two separate 600 gallon tanks mounted on a trailer frame. These trucks are Department of Transportation (DOT) approved for transportation of bromine. Bromine is unloading into a 1000 gallon lead lined steel bulk storage tank using nitrogen pressure off-loading. Bromine is stored in two indoor storage tanks, one tank for each of the distinct manufacturing processes. All bromine bulk storage is located within concrete diked areas that are enclosed and continuously monitored for bromine vapors (continuous air monitoring systems are in place for each bulk storage and processing area. Each storage facility is equipped with a water d eluge system and ammonia gas delivery system to neutralize vapors. The concrete containment dikes maintain a layer of water (or water blanket) which, should a release of bromine enter the dike, the water will suppress any bromine vapors thus providing passive mitigation. The bromine handling system (bulk tank, receiver and reactor) is vented to a scrubber to prevent atmospheric discharges. Water fog nozzles are located at the tank truck unloading containment area for additional active mitigation and suppression of vapors. Liquid bromine is transferred from the 1000 gallon bulk storage tanks by nitrogen pressurization into receiver vessels. The bromine is mixed with other reactants in the reactor to produce a processing intermediate. In case of overpressurization, the receivers are vented to concrete dike areas where containment and passive mitigation control (water blanketing) are present. The liquid bromine is then transferred from the receiver vessel to a reactor by gravi ty through approved piping. The reactor is equipped with pressure relief venting. Pressure is preceded by alarms. Should a rupture disc (pressure relief) open as designed to relieve pressure, the process would vent into a concrete diked area where containment and passive mitigation control (water blanketing) is present. 3. The worst-case release scenario(s) and the alternative release scenario(s), include administrative controls and mitigation measures to reduce quantities of material released and thus limit the distances for each reported scenario. Worst-case Release Scenario. Failure of a bromine Bulk Storage Tank when filled to the greatest amount would release 26,000 pounds of bromine. It is also assumed that the entire contents of the tank are released as a liquid into the diked containment area located indoors. Passive mitigation measures in place include: 7 Diked storage areas. 7 Indoor enclosure of storage tanks. 7 Diked storage area continually contains a layer of water which, will form a vapor blanket should there be a liquid bromine release from the tank. 7 Bermed tanker unloading areas with drainage directed to diked area. 7 Passive mitigation measures reduce "worst case" quantity of material released from processes to less than 0.004 pounds per minute. Active mitigation measures in place include: 7 Bromine storage and handling facilities are equipped with water deluge and ammonia vapor neutralizing/suppression systems which are designed to condense, precipitate and contain vapor or liquid bromine releases. 7 In-plant emergency response/HAZMAT team. 7 Water fog nozzles are located at the tank truck unloading containment area for additional active mitigation and suppression of vapors. With passive mitigation measures in place, the ALOHA (Area Locations of Hazardous Atmosphere) calculated distance to the endpoint concentration of 0.0065 mg/L (ERPG2) is 30 yards and does not exceed the facility fence line. Calculations are ma intained on file at Lord CPD. Alternative Release Scenario. An Alternative Release Scenario is not required for this Program Level I submittal. 4. The general accidental release prevention program and the specific prevention steps. This facility complies with EPA's Accidental Release Prevention Rule, the OSHA Process Safety Management (PSM) standard, and all applicable state codes and regulations. 5. Five-year accident history. We have not had any bromine releases that qualify for listing in the EPA's required five-year accident history report. 6. The emergency response program. We have coordinated our program with the local emergency planning committee (LEPC), Crawford County Office of Emergency Management (OEM), Crawford County Hazardous Materials Team (HAZMAT) and the Saegertown Volunteer Fire Department. Representatives of the OEM visited this plant on March 24, 1999. Representatives from the HAZMAT Team visited this plant on April 8, 1999. Representatives from t he Saegertown Volunteer Fire Department visited this plant on May 12, 1999. During the above visits, we discussed how to respond to a release of Bromine and conducted a general facility tour. We have also given local hospitals information regarding medical treatment for exposure to Bromine. |