DuPont Yerkes Plant - Executive Summary |
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DUPONT YERKES PLANT - EXECUTIVE SUMMARY INTRODUCTION At the DuPont Yerkes Plant, we use a combination of accidental release prevention and emergency response planning programs to help ensure the safety of our employees and the public, as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: 7 Accidental release prevention and emergency response policies 7 Facility description and substance regulated by Risk Management Plan (RMP) regulation 7 Worst-case and alternative-case release scenarios 7 Five-year accident history for accidental releases of RMP chemicals 7 General accidental release prevention program and chemical-specific prevention steps 7 Overview of our emergency response program 7 Planned facility changes to improve safety and prevent accidental releases ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The DuPont Yerkes plant is commi tted to operating and maintaining all of our processes in a safe and responsible manner. A guiding principle, as stated in our Yerkes Vision Statement, is "We will perform our jobs in a manner that ensures the safety and health of ourselves and our fellow employees and protects the site facilities and the environment of our community." The DuPont Yerkes Plant adheres to Corporate policies. These policies are embodied in numerous Safety Health & Environmental and Engineering Standards, which apply globally. These standards can be summarized as follows: 7 All Safety and Environmental incidents are preventable. 7 The Goal is Zero - Zero Incidents, Period. 7 All employees and contractors are responsible for their safety. FACILITY DESCRIPTION AND SUBSTANCE REGULATED BY RMP REGULATION The Yerkes plant covers approximately 100 acres in a highly industrialized section of the Town of Tonawanda, NY. The facility is fully fenced and monitored 24 hours a day by a security force. Various products have been manufactured on the site since 1921. Currently, the site consists of two manufacturing processes: 7 Tedlar. polyvinyl fluoride films 7 Corian. sheet and shape filled acrylic building materials The EPA has identified VINYL FLUORIDE (VF), which is flammable, as the only chemical at Yerkes which has the potential to cause significant offsite consequences in the event of a substantial accidental release. WORST-CASE AND ALTERNATIVE-CASE RELEASE SCENARIOS EPA's Risk Management Plan (RMP) regulation requires that we provide information about the worst-case release scenario and alternative release scenario for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Vinyl Fluoride, Regulated Flammable Chemical The worst-case release scenario is a failure of one of our two independent and iden tical Vinyl Fluoride storage tanks, with no mitigation assumed. This release, if ignited, would result in a vapor cloud explosion that would have an off-site impact as determined by the use of the Offsite Consequence Analysis Guidance. In the event of a release there should be no public receptors. A release is unlikely due to the construction and high-integrity design of the tanks / associated equipment, and the dual water deluge / emergency tower venting systems. Alternative Release Scenario - Vinyl Fluoride, Regulated Flammable Chemical The alternate-case release scenario is a failure of a flex hose during unloading of Vinyl Fluoride from a tank truck to a storage tank, with no mitigation assumed. This alternative-case scenario was selected because of the frequency of truck unloading. The release rate is based on the maximum flow than can occur before the excess flow valve self actuates. The duration of the release is based on a conservative estimate of the time needed to shu t down the unloading operation. This release, if ignited, would result in a flash fire that would have an off-site impact as determined by the use of the Offsite Consequence Analysis Guidance. In the event of a release there should be no public receptors. A release and subsequent flash fire is unlikely because of the tank truck excess flow valve, automatic shutdown equipment and procedures, and the construction and high-integrity design of tank trucks and associated unloading / transfer equipment. Also, preventive maintenance of the hoses and used of checklists reduces the possibility of a unloading hose failure. FIVE-YEAR ACCIDENT HISTORY FOR ACCIDENTAL RELEASES OF RMP CHEMICALS Within the past five years, the Tedlar. process has had no accidental release that caused offsite impacts provided in the Risk Management Plan regulation, (40 CFR 68.10(b)(1)). Records are kept for all Serious Incidents (non-standard operations) that occur at our facility. For every Serious Incident, we conduct a formal incident investigation to identify and correct the root causes of the event. Although there have been Serious Incidents, none have resulted in a RMP incident in the 37 years of Tedlar. operations. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND VINYL FLUORIDE SPECIFIC PREVENTION STEPS Yerkes accidental release prevention programs and contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of Vinyl Fluoride. The site takes a systematic, proactive approach to prevent accidental releases of Vinyl Fluoride. The process to react Vinyl Fluoride to form polyvinyl fluoride follows the requirements of the DuPont Corporate "Process Safety Management" (PSM) standard. This standard includes and embraces the requirements of 29 CFR 1910.119 and 40 CFR Part 68. Yerkes management systems address each of the key features of the layers of protection necessary for a successful preventio n program including: 7 Equipment Specifications - Follow industry specific standards - Document design specifications and calculations for storage tanks, piping, safety relief valves and other Process Safety Management critical equipment - Tank trucks are equipped with an excess flow valve 7 Training - Operational, mechanical and contractor personnel working with or close to VF equipment are trained per OSHA standards - Emergency response personnel are trained and qualified to the 24 hour Technician level per 29 CFR 1910.120(q)(6)(iii) 7 Operating And Safety Procedures - Changes to procedures use the management of change procedure per OSHA standard - Operating procedures are reviewed and verified by Job Cycle Checks - Specific checklists and/or procedures for PSM critical operations are maintained - PSM critical operating procedures are authorized yearly per OSHA standard - Pre-start up safety reviews are conducted on new or modified equipment - A cargo tank truck inspection che cklist is used before Vinyl Fluoride unloading begins - Remote continuous ambient Vinyl Fluoride monitoring is performed - Operator is present 100% of the time to observe unloading operations 7 Maintenance Inspection Systems - All PSM critical equipment is set up on a periodic inspection frequency - Mechanical work plans are reviewed via the work order system - Tank trucks are dedicated and inspected and maintained per 49 CFR 180.407(c) - Preventative Maintenance (PM) is performed routinely on existing equipment 7 Safety And Emergency Systems - Process hazards reviews are performed every 5 years per OSHA standard - Serious incident investigations are held for non-standard events to correct root cause - An emergency venting tower will convey Vinyl Fluoride away from the area to prevent a build up of flammable gas - Remote "fail safe" air operated valves can isolate the unloading operation, storage tanks and shut down operations - Tank farm and barricade are covered by dual 600 GPM wat er deluge systems - Storage tanks and reactor vessel are continuously monitored for temperature and pressure and an alarm will sound if above standard conditions occur - A computerized work order system, that issues PMs, is used to track inspections of all VF hoses, flame arrestors, rupture disks and relief valves OVERVIEW OF OUR EMERGENCY RESPONSE PROGRAM Yerkes maintains an integrated emergency control plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. The site program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the Town of Tonawanda, NY Emergency Services. Our program can be summarized as follows: 7 Tedlar. Specific Procedures - Emergency shutdown procedure for an uncontrolled reaction, explosion, or fire - Emergency shutdown for a VF leak inside the Polymer Area barricade - Emergency shutdown for a VF leak outside the Polymer Area barricade 7 Yerkes Emergency Control Plan - Overview - Plant fire alarm is sounded in area of emergency and emergency responders report - Disaster alarm sounded as needed and Emergency Control Plan activated - Central and Field Control Organizations report - Community emergency responders are notified as appropriate. 7 External Resources - DuPont maintains a regional Transportation Emergency Response Team in near by Niagara Falls, NY - Yerkes maintains a contract with OHM Corporation for emergency response - Yerkes is a member of the local Hazardous Materials Advisory Council for mutual aid. - Local fire departments 7 Training and Preparation - Yerkes personnel receive emergency response training - Yerkes emergency responders are 24 hour Technician Level trained - Yerkes holds site emergency drills and participates in community drills - Community and contract emergency responders tour the Yerkes Plant - Yerkes Risk Management Plan has been presented to Erie County LEPC PLANNED FACILITY CHANGES TO IMPROVE SAFETY AND PREVENT ACCIDENTAL RELEASES The following is a list of improvements that we are planning to implement at Yerkes to help prevent and/or better respond to accidental chemical releases: 7 Upgrade the Vinyl Fluoride tank truck unloading pump design 7 Upgrade the Vinyl Fluoride ambient monitor to a model with faster sample frequency 7 Upgrade the Vinyl Fluoride ambient monitoring system with additional sampling locations 7 Upgrade the Vinyl Fluoride piping materials of construction |