Air Products and Chemicals, Inc. - Main Plant - Executive Summary

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Calvert City Plant  Main Production Facility 
Risk Management Plan  
Executive Summary 
1.  Accidental release prevention and emergency response policies: 
The Air Products and Chemicals (APCI) plant, which is located on Highway 95 in Calvert City, is a Program 3 facility in the Environmental Protection Agencys (EPA) Risk Management Plan (RMP).  Under RMP, the Calvert City plant is classified as two sources:   
1.  The main plant stationary source on Highway 95 and   
2.  The storage, pipeline and barge unloading source at the Tennessee River.   
The largest quantity feedstock, Vinyl Acetate Monomer (VAM), is used in the production of polyvinyl alcohol (PVOH) and latex emulsions.  Ethylene and Vinyl Chloride Monomer (VCM) are also used in the production of latex emulsions. VAM, VCM and ethylene, in the quantities handled at this facility, are considered hazardous by EPA under the Risk Management Rule.  
Air Products and Chemicals, Inc. (APCI) is committed to continuous improvement in a 
ll aspects of safety and environmental performance.  It is our policy to adhere to all applicable Federal, Commonwealth of Kentucky and local rules and regulations.  The APCI Plant Manager at the Calvert City plant is responsible for facility operation.  The APCI Environmental Manager reports to the Plant Manager and has overall responsibility for compliance with all aspects of the facilitys Risk Management Plan.  APCI Environmental, Health and Safety (EH&S) operates under a tiered Management System, with policies and procedures cascading from Corporate requirements to detailed plant operating and safe work practices.  As a member of the Chemical Manufacturers Association (CMA), APCI subscribes to the Responsible Care program and has conducted a Management Systems Verification by outside reviewers   
As a site that is in compliance with the OSHA Process Safety Management (PSM) regulation, the Calvert City plant strives to prevent chemical emergencies.  Prevention of chemical emergenc 
ies includes specifying that all equipment, piping, vessels, tanks, etc. meet all applicable design codes and specifications.  Documentation of these codes and specifications form the basis of our process safety information including flow diagrams, piping and instrument diagrams, process descriptions, and other documentation. Trained and qualified employees work with sophisticated control systems that include instrumentation, alarms and shutdowns to keep our processes operating in safe limits that minimize adverse impacts on the employees, the surrounding community , and/or the environment.  
Operating instructions, startup/shutdown instructions and consequences of deviation define required operating conditions and steps needed to control normal and out-of-normal conditions. 
Under PSM, employee involvement in all aspects of plant operations, its safety and environmental programs is required and met at the Calvert City plant.  Employees are regularly trained, certified, and subject to  
random substance abuse checks to ensure the safety of the plant.  Our safety process contains many other elements including management of change, hot work procedures and regular process hazards analysis using the hazard and operability (HAZOP) tool.  All contractors working at the plant are subject to the same rules and procedures that APCI employees must follow under the contractor safety program.   
The emergency response plan includes Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER)  training and qualifications for on-site employees.  APCI participates in a partnership among the Calvert City area industries named the Calvert City Industrial Mutual Aid Program or CIMAP.  This organization collaborates with community emergency responders and citizens to form a strong Local Emergency Planning Committee or LEPC.  APCI is an active member of the LEPC and the Calvert City community. 
This document has been prepared in accord 
ance with the EPAs RMP regulation          (40 CFR, Part 68). The substances and processes considered during the preparation of this document, the scenarios described, and modeling techniques selected were chosen  based on the criteria established in the regulation. 
2.  The stationary source and regulated substances handled:  
The stationary source is the APCI main production facility located on Highway 95 in Calvert City, Kentucky. The three RMP covered processes are the Polyvinyl Alcohol (PVOH) unit, the Emulsions unit, and the VAM storage and distribution unit.   
In the PVOH unit, VAM is polymerized in a solvent to make polyvinyl acetate (PVAc).  PVAc is converted to polyvinyl alcohol (PVOH), which is ground to a granule, dried, stored, packaged and shipped in bags, trucks and railcars.  PVOH is a water soluble powder that is used in applications such as water-based adhesives and to protect fibers as they are woven to fabrics.  
In the Emulsions unit, VAM is polymerized in water  
to polyvinyl acetate (PVAc), Ethylene and/or  vinyl chloride monomer (VCM) may also be polymerized in water with or without VAM.  A number of other chemicals that are not covered by the RMP regulations, may be used to adjust the properties for specific end uses.  Emulsions products are used in many applications including adhesives, latex paints and paper coatings. 
The VAM storage and distribution area at the main production facility receives VAM from tanks at the Tennessee River and stores it on site to continuously supply the PVOH and Emulsions production facilities.   
The regulated substances handled at this stationary source are: 
1.  Vinyl Acetate with the maximum quantity in an individual storage tank of   433,000 pounds. 
2.  Ethylene with the maximum quantity in an individual storage tank of            237,000  pounds 
3.  Vinyl Chloride with a maximum quantity in an individual process of       60,000 pounds.  
3.  The "worst case scenarios and alternative release scenarios, inc 
luding administrative controls and mitigation measures that limit the distance for each reported scenario:  
The Air Products and Chemicals plant at Calvert City has one RMP listed toxic liquid, Vinyl Acetate Monomer and two RMP listed flammables on site, Ethylene and Vinyl Chloride Monomer.  Because the explosive release of energy is greater for ethylene than VCM, ethylene was chosen as the source for the flammable scenarios.   
In the plant, the greatest VAM inventory is contained in either of two storage tanks,    FB-1510 and FB-1511.  Under worst case conditions of a single tank failure, the entire contents of the tank, 436,800 pounds of VAM would be released from the tank and be contained in an earthen dike around the tanks. Using the EPA lookup tables for rural terrain, the vaporized VAM would spread to an endpoint that would exceed plant boundaries.  Although there are active controls directed at preventing such a release and controlling the consequences, no credit was taken for 
active mitigation methods in evaluating this Worst Case Scenario.  
The alternative case for a toxic liquid at the plant is the overpressure of a PVOH polymerization  reactor and a subsequent VAM release from the pressure relief system.  A similar incident occurred at Calvert City in 1992 and at a similar facility in 1996. It was calculated that 5,900 pounds of VAM were released and vaporized to the environment. Using the EPA lookup tables and default weather conditions, the radius to the endpoint would exceed plant boundaries.  Even though the EPA methodology would allow credit for active mitigation methods, no such credit was taken.  
The PVOH  polymerization reactors are provided with safety systems, including; computer control and monitoring of all process parameters, dilution methanol addition, DEHA reaction stopper injection, cooling water, dual pressure relief systems and a catch tank or vent collection system.  If any or all of these prevention systems operates as designed, th 
e radius to the endpoint would be significantly reduced.  Calvert City has had three of these types of releases and two near misses in the last fifteen years.  None have had any off-site impact, employee injuries or equipment damage that would qualify as an RMP incident.  
The worst case RMP flammable scenario is the release of the contents of the liquid ethylene storage tank. Ethylene is delivered to the plant in a  railcar or tank truck and stored as a liquid under pressure.  Liquid ethylene storage capacity is administratively controlled to 90% of tank capacity or 237,400 pounds.  Under worst case conditions, a tank failure would release 237,400 pounds of ethylene.  The distance to a 1.0 psi overpressure endpoint would exceed plant boundaries using the EPA lookup tables.  
The alternative case scenario would be the failure of the 2" ethylene unloading hose.  Using the total contents of the railcar (138,500 lbs) under average weather conditions, an explosion would have an impact to a 
n endpoint with off-site consequences. Even though the EPA methodology would allow credit for active mitigation methods,  no such credit was taken. The safety systems associated with ethylene unloading work include an operator in constant attendance during unloading, two excess flow check valves for shutdown, vapor monitoring and alarm. These and other safety measures would reduce the size of the release and the distance to the endpoint.   
Because VCM has less explosive energy and is stored in smaller quantities, VCM was not selected for any of the RMP scenarios or hazard assessments.   
4.  The general accidental release prevention program and specific prevention measures: 
Key to the plants prevention programs are the layers of protection provided at each process.  The hierarchy starts with the facility design and construction which is to all applicable design standards using qualified engineers and contractors. A comprehensive mechanical integrity program includes routine checks o 
f all process equipment, tanks, vessels and piping.  These checks are done using nondestructive testing techniques and kept in the permanent equipment files.   
Trained operators working with current operating procedures and process safety information keep the processes operating safely and in environmental compliance.  Control systems and instrumentation provide the tools to keep the process within these limits and provide the information and control to properly operate each process in normal, startup/shutdown and emergency conditions.  Instrumentation alarms alert plant operators to deviations and provide early warning to process upsets.  
In the event an upset leads to an uncontrolled condition, process safety devices including critical interlocks that activate automatic shutdowns, pressure relief valves, rupture disks, and flame arresters are in place to safely control upset conditions.  Process areas are covered by fire sensors and flammable vapor sensors, fire sprinklers systems, 
monitor nozzles, dry chemical extinguishers, etc.  Containment dikes around storage tanks and process areas are curbed to contain small spills and direct them to drains to the plants chemical sewer and the wastewater treatment plant.   
Each process design is subject to detailed process hazard reviews during design, construction and startup. All process changes must be reviewed and approved under a detailed Management of Change procedure before any changes are made.  At periods not to exceed five years, Operational Plant Hazard reviews are conducted by teams of supervisors, engineers, operators, mechanics and safety professionals. 
The elements of the prevention program are audited regularly at the production unit, plant and corporate levels.  These audits are documented as part of the basic safety process with corrective action defined and tracked through the plant management systems.  
5.  Five year accident history:  
None of the stationary sources or covered processes at the Air  
Products and Chemicals plant at Calvert City has had an incident in the last five years that would be reported under RMP.  There have been no releases of VAM, ethylene or VCM that have had any off-site consequences, resulted in any employee injuries, or resulted in any significant equipment damage.   
6. The emergency response program:  
The facilitys emergency response program is based on the OSHA HAZWOPER standard. There are at least 16 trained emergency responders in the fire and rescue squad that are divided into shifts and day workers.  Each shift has a fire and rescue squad that is led by the shift safety officer.  In an emergency, the safety officer assumes on-scene command of any incident.  On-site emergency resources include a fire/foam truck, a rescue truck and ambulance.  In addition to these resources, APCI is a member of the Calvert Industrial Mutual Aid Program (CIMAP) and can count on pooled resources from surrounding plants and communities.  As a member of the LEPC, AP 
CI regularly stages emergency response drills both in-house and outside with emergency responders from the public and private sector.  LEPC members and other emergency responders regularly tour the facility to familiarize themselves with the plant, its hazardous materials, equipment, layout, personnel and emergency procedures.        
7. Planned changes to improve safety:   
The process safety information and systems are evaluated regularly through the Operational Plant Hazard Reviews, with industry-wide changes in standards and as a result of incidents that have occurred within the chemical industry. The vinyl acetate storage tanks have no outstanding upgrade recommendations. The liquid ethylene unloading system and storage tank have no outstanding upgrade recommendations.  The PVOH polymerization reactors and mitigation systems have no outstanding recommendations. 
The emergency notification and response systems  are composed of a siren system that is activated by the 911 operator ba 
cked up by the safety officer at Air Products.  In the event of an emergency, 911 would activate the sirens and voice control modules that are placed in public buildings such as the convalescent center, city hall and the Calvert City Elementary school.  Once a citizen has heard the siren, they are to turn their radio on the local Calvert City station (WCCK) and listen for specific instructions.  The sirens are routinely tested one day per month and training in the community has been ongoing for almost one year.
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