Sterling Fibers, Inc. - Executive Summary

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Sterling Fibers, Inc. 
Accidental Release Prevention and Emergency Response Policies 
The accidental release prevention and emergency response policies at the Sterling Fibers Inc. (Sterling Fibers) Santa Rosa County Florida facility (Santa Rosa Plant) are ingrained in the fundamentals of the process safety management process. 
At our Santa Rosa Plant we presently handle two chemicals which are considered hazardous by the Environmental Protection Agency (EPA).  The same properties that make these chemicals valuable as commodities in the production of consumer products also make it necessary to observe specific safety precautions.  These safety precautions are exercised in the handling and production processes to control human and environmental exposure in an effort to reduce the overall threat to employees as well as the surrounding community. 
It is Sterling Fibers' policy to adhere to all applicable federal, state and local laws, rules, and regulations.   Safety depends upon our mana 
gement commitment, the manner in which we handle and process chemicals, the safety devices inherent to our process designs, our operating procedures and philosophies, and the training of our workers. 
We believe that accountability for safety reaches throughout all levels of management at Sterling Fibers.   Senior management's commitment and dedication to continued safe operating practices is clearly evident in the oganization structure and employee empowerment.  This is no more evident than in our involvement in the OSHA Process Safety Management (PSM) program.  Our commitment to PSM standards is a strong example of management's commitment to continuously make the Santa Rosa plant a safe worksite. 
We have made extensive improvements to safety and health programs like process safety management, emergency preparedness and response, hot work permitting, and training.   
Additionally, we believe employee involvement is the cornerstone to continued safe operations.  We call it employee ow 
nership and its success is portrayed through our lower injury rates, fewer incidents, and improved operating efficiencies at the Santa Rosa Plant.  Our employees volunteer to participate in a unique program known as "Sterling Teams to Enhance Plant Safety" (STEPS).  There are currently four active STEPS teams at the Santa Rosa Plant.  They are: a) Plant Safety Steering, b) S*A*F*E Steering, c) Contractor Safety, and d) PSM.  The teams present summary reports of their activities and improvements to senior management each quarter. 
The Emergency Preparedness and Response Plan outlines procedures for warned and unwarned emergencies that may occur at the plant.  Warned emergencies are usually of the natural type, such as hurricanes, or freezes.  Unwarned emergencies usually consist of on-site emergencies such as spills, fire, explosion or a chemical release.  As a responsible company, Sterling Fibers provides the emergency response teams with state-of-the-art equipment and the latest train 
ing and procedures.  This ensures prompt mitigation actions during incidents and rapid notification to any surrounding neighborhood that may be inadvertently affected by a plant emergency.   
We maintain policies and procedures covering response teams that make up the overall emergency preparedness and response program for the plant.  The plant has created several teams to respond to various emergencies.  The Plant Emergency Response Team (PERT) is comprised of volunteer individuals from various departments that perform assigned functions in their aligned areas.  The team is also known as the Fire Brigade and is broken down as: a) Fire Response, b) Rescue Response, and c )HazMat Support.  These organizations are highly trained to handle fire, medical, spill, and rescue emergencies and capable of responding to onsite and offsite emergencies.  In addition, Sterling Fibers participates in local fire and industrial mutual aid systems and is an active member of the Santa Rosa County Emergen 
cy Management and the District 1 Local Emergency Planning Council (LEPC). 
Facility Description and Regulated Substances Handled 
Sterling Fibers is a wholly owned subsidiary of Houston, Texas based Sterling Chemicals, Inc.  The Santa Rosa Plant produces acrylic fiber from monomeric acrylonitrile and vinyl acetate.  Sterlings' synthetic acrylic fibers, which are non-toxic, are used for such consumer products as apparel, blankets, upholstery, and carpets. 
The Sterling Fibers Santa Rosa Plant is located in Section 31, Township 1 North, Range 29 West in Santa Rosa County, about 15 miles northeast of Pensacola.  The plant's physical address is 5005 Sterling Way, Pace, Florida, Santa Rosa County. 
The Santa Rosa Plant employs approximately 281 staff and 57 contract personnel and currently operates 24 hours per day, seven days per week. 
We presently handle three regulated chemicals which are considered hazardous by EPA, Acrylonitrile, Vinyl Acetate Monomer, and Chlorine.  However, only Ac 
rylonitrile and Vinyl Acetate Monomer are present in quantities greater than the threshold quantity identified by the RMP regulation and therefore are included in our risk management program.   
In addition, Sterling Fibers, Inc. is subject to Occupational Safety & Health Administration (OSHA) Process Safety Management (PSM) and is classified under a listed SIC Code (2824).  Therefore, the two Sterling Fibers' processes are classified as Program 3 processes under the Accidental Release Prevention Program.   
Acrylonitrile - Acrylonitrile is used in acrylic fiber stock and made into fabric.  It is stored at the plant in storage tanks at ambient pressure. 
Vinyl Acetate Monomer - Vinyl Acetate Monomer is used in acrylic fiber stock and made into fiber.  It is stored at the plant in storage tanks at ambient pressure.   
Offsite Consequence Analysis (worst-case & alternate cases) 
EPA's Risk Management Program (RMP) requirements for identification and selection of a worst-case hazard scena 
rio are prescriptive and negate most safety systems designed to mitigate an incidental release.  Based on EPA defined Offsite Consequence Analysis (OCA) parameters, Sterling Fibers has one worst-case hazard scenario for the toxic materials handled on-site.  It involves Acrylonitrile.  This scenario is estimated to create the greatest distance in any direction to an EPA defined concentration (endpoint) resulting from an accidental release. 
Worst-Case Scenario 
The worst-case scenario is a hypothetical release of the largest quantity of any of the hazardous materials listed under the RMP rule as determined by EPA.  The EPA mandates companies presume the release of the entire quantity of the substance.  Only passive mitigation efforts such as those controls in place that do not require action by an employee to inititate are allowed to be considered.  An example of passive mitigation is diking which provides a secondary containment system designed to contain 110% of all chemical leaks/spi 
lls and to prevent any chemicals from getting to the groundwater or surface water.   
Toxic Substances:  Toxic endpoints are listed in Appendix A to 40 CFR Part 68 (Table of Endpoints).  Each of the regulated toxic substances at Sterling Fibers was reviewed to determine the substance with the greatest distance to endpoint.  Based on the EPA lookup tables, a worst-case release of acrylonitrile results in a distance to the toxic endpoint of 1.1 miles.  The worst-case scenario for acrylonitrile assumes the total failure of a single storage tank into a diked area with the maximum possible amount (745,000 lbs) in the tank at the time of its failure.   
Flammable Substances:  None 
Alternate Release Scenario 
The EPA rule also prescribes that alternate or more likely accident scenarios involving regulated chemicals are identified.  Alternate release scenarios are those that are more likely to occur than the worst-case release scenario.  Alternate release scenarios for toxic substances shoul 
d be those that lead to concentrations above the endpoint beyond the facility's fence line.  Conditions considered for alternate release scenarios are:  a release rate dependent upon scenario; use of typical meteorological conditions at the stationary source; the actual release height; and consideration of active and passive mitigation systems.  Facilities are allowed to include active mitigation.  Active mitigation includes procedures and equipment which are used to contain or minimize the impact of an accidental release.  Examples of active mitigation are an employee turning off a valve or using a spray hose to knock down vapors. 
Toxic Substances:  One alternative release scenario for each toxic substance is required under the ARP program.  A hypothetical release scenario has been identified for the regulated toxic substances at Sterling Fibers to determine the distance to an endpoint for each.  Based on the EPA lookup tables, the substances and the distances to toxic endpoints are: 
 Acrylonitrile (.2 miles) and Vinyl Acetate Monomer (.1 mile).   
Flammable Substances:  None 
Accidental Release Program and Chemical -Specific Prevention Steps 
At Sterling Fibers, processes regulated by the EPA's RMP regulation are also subject to OSHA's PSM standard, and a brief summary of each OSHA PSM element is provided:   
1)  Employee Participation:  Sterling Fibers encourages employees to participate in all facets of process safety management and accident prevention.  Examples of employee participation range from updating and compiling technical documents and chemical information to participating as members of process hazard analysis (PHA) teams.  In addition, Sterling Fibers has a number of initiatives under way that address process safety and employee safety issues.  The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management. 
2)  Process Safety Information:  Sterling Fibers keeps a variety of tec 
hnical documents that are used to help maintain safe operation of the processes.  Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information.  Sterling Fibers maintains chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, as provided in material safety data sheets (MSDSs).  This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals.  The plant also maintains numerous technical documents that provide information about the design and construction of process equipment.  This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.   
3)  P 
rocess Hazard Analysis (PHA):  Sterling Fibers has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled.  Within this program, each process is systematically examined to identify hazards and ensure the adequate controls are in place to manage these hazards. 
Sterling Fibers primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations.  HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques.  The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise.  This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. 
The PHA team findings are forwarded to management for resolution.  Impleme 
ntation or mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team.  This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention.  To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, Sterling Fibers periodically updates and revalidates the hazard analysis results. 
4)  Operating Procedures:  Sterling Fibers maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process.  These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators.  The procedures are kept current and accurate by revising them as necessary to reflect changes made through the manage 
ment of change process. 
5)  Training:  To complement the written procedures for process operations, Sterling Fibers has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in plant operations if they are not already familiar with such operations.  In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. 
6)  Contractors:  Sterling Fibers uses contractors to supplement its workforce during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment, the plant has procedures in place so that contractors (1) can perform their work in a safe manner, (2) should have the appropriate knowledge and skills to perform their work safely, (3) can be aware of the hazards in their workplace, (4) should understand what they should do in the ev 
ent of an emergency, (5) should understand and follow site safety rules, and (6) should inform plant personnel of any hazards that they find during their work.  This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work.  In addition, Sterling Fibers evaluates contractor safety programs and performance during the selection of a contractor.  Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. 
7)  Pre-Startup Safety Reviews (PSSRs):  Sterling Fibers conducts a PSSR for any facility modification that requires a change in the process safety information.  The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service.  This review provides 
one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready.  The PSSR review team uses checklists to verify all aspects of readiness.  A PSSR involves field verification of the the construction and serves a quality assurance function by requiring verification that accidental prevention program requirements are properly implemented. 
8)  Mechanical Integrity:  Sterling Fibers has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition.  The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures.  In combination, these activities form a system that maintains the mechanical integrity of 
the process. 
9)  Hot Work Permits and Other Safe Work Practices:  Sterling Fibers has long-standing safe work practices in place to help ensure worker and process safety.  A hot work permit system is used to control potential ignition sources.  Other procedures include:  confined space entry; lockout/tagout to ensure isolation of energy sources; work permits to assure safe removal of hazardous substances before process piping or equipment is opened; and personal protective equipment to provide employee protection.  Training of personnel in safety procedures helps ensure that operations and maintenance activities are performed safely. 
10)  Management of Change (MOC):  Sterling Fibers has a comprehensive system to manage changes to all covered processes.  This system addresses change to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented.  Ch 
anges are reviewed to (1) ensure that adequate controls are in place to manage any new hazards, and (2) verify that existing controls have not been compromised by the change.  Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. 
11)  Incident Investigation:  Sterling Fibers promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury.  The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. 
12)  Compliance Audits:  To help ensure that the accident prevention program is functioning properly, Sterling Fibers periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented.  Both hour 
ly and staff personnel participate as audit team members. 
13)  Chemical-Specific Prevention Steps:  The processes at Sterling Fibers have hazards that must be managed to ensure continued safe operation.  Sterling Fibers has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. 
14)  Universal Prevention Activities:  The accident prevention program summarized previously is applied to all RMP-covered processes at Sterling Fibers.  Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. 
Five Year Accident History 
Sterling Fibers has not had any accidental releases during the past five years which meet the criteria for an accidental release per 40 CFR 68.42. 
Emergency Response Information 
Sterling Fibers maintains a written emergency response plan to protect worker and public safety as w 
ell as the environment during an emergency.  Sterling Fibers recently developed an Integrated Contingency Plan (ICP) for the Santa Rosa Plant, as part of EPA's one plan guidance to centralize standards to protect human health, safety, and the environment.  The ICP addresses the emergency planning and response requirements of the following regulations and standards: (1) Florida Administrative Codes 62-710 and 62-730 and EPA's Resource Conservation and Recovery Act (RCRA) Contingency Planning Requirements - 40 CFR Part 264, Subpart D, 40 CFR Part 265, Subpart D, and 40 CFR 279.52; (2) EPA's Oil Pollution Prevention Regulation (SPCC Plan Requirements) 40 CFR Part 112; (3) OSHA's Emergency Action Plan - 29 CFR Part 1910.38(a); (4) OSHA's Process Safety Management (PSM) Standard - 29 CFR Part 1910.119; (5) the emergency response portion of OSHA's HAZWOPER - 29 CFR Part 1910.20; and (6) incorporates the requirements of EPA's Risk Management Program - 40 CFR Part 68.   
The structure of Sterl 
ing Fibers' ICP and annexes are largely based on the structure of the National Interagency Incident Management System (NIIMS) Incident Command System.  This is a type of response management system that has been used successfully in a variety of emergency situations including releases of oil or hazardous substances.  It is a nationally recognized system currently in use by numerous federal, state, and local organizations. 
Sterling Fibers' ICP consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion.  The procedures address all aspects of emergency response, including first aid and medical treatment, evacuation and accounting for personnel, notification of local emergency response agencies and the public if a release occurs, incident mitigation and post-incident cleanup and decontamination requirements.  The plant routinely performs maintenance on emergency equipment including tests and inspections and provides employe 
e training on equipment use.  Employees receive training as necessary to perform their specific emergency response duties.  The ICP is updated when necessary based on modifications made to plant processes, equipment, and design. 
Sterling Fibers maintains a highly trained Plant Emergency Response Team (also known as the Fire Brigade) to handle fire, medical, spill, and rescue emergencies within the plant.  The Fire Brigade is all volunteer and consists of 25 team members (5 members per shift including supervision).  It also participates in local fire and industrial mutual aid systems. 
The overall emergency response program for Sterling Fibers is coordinated with the Santa Rosa County Emergency Management officials and 911 system, the Avalon Beach - Mulat Volunteer Fire Department, and the Milton Fire Department.  Periodic meetings with response agency personnel are conducted to discuss needs and concerns in the event of an incident at the plant.  Sterling Fibers has 24-hour communicat 
ions capability with State and Federal agencies and with local emergency response agencies through a designated emergency phone system to access additional emergency equipment and services (i.e., firefighting equipment, manpower, ambulances, hospitals, law enforcement, and HAZMAT operations).  Notifications to the public by local officials can be accomplished through an automatic community alerting phone system, which Sterling Fibers and other local industries provide to the Santa Rosa County Emergency Management Office. Sterling Fibers conducts periodic emergency drills that involve local emergency response organizations.   
Planned Changes to Improve Safety 
Sterling Fibers has several elements of the management system of the accidental prevention program in place to improve safety throughout the facility.  These elements are part of an overall ongoing safety improvement process at the plant.   
The MOC/PSSR Procedure is being reviewed in an effort to make the system more clearly de 
fined and to continue the MOC and PSSR process.  The result will be a more "readable" document with improvements in clearly defined roles and responsibilities.  Additionally, forms and guides will be changed to enhance the purposes of the procedure and provide consistency of performance.  Combining the MOC and PSSR procedures will provide for a more natural workflow and will improve the emphasis on performance of PSSR's as a result of completing the MOC review. 
The requirements set by the MOC/PSSR components of Sterling Fibers' PSM process are rigid and extensive by design in order to provide a good foundation for these two elements.  Improvements in these two areas of PSM will come by achieving closer adherence to the requirements of both components. 
A significant improvement for hazard reporting will be the development of the SAFE database.  The database allows electronic input of safety suggestions and hazards and a way to track them until resolved.  The database will also provide 
a means to evaluate trends in employee suggestions and reported hazards in the future.  Further use of this database will enhance the ability of the plant to initiate programs to address the suggestions made or correct the hazards reported.   
Improvement plans for Sterling Fibers' accident/incident investigation process include: 
Sterling Fibers is in the process of developing a PSM awareness program on which all employees will be trained.  Information on the accident/incident investigation process will be included in the training package.  This will make employees more aware of opportunities for participation, access of investigation reports, etc. 
The method by which recommendations arising from investigations are tracked will be improved.  Plans for improvement focus on improving our system for tracking recommendations generated by the investigation process and contained in the formal reports. 
Sterling Fibers is currently seeking/evaluating software systems that will allow those  
who are responsible for corrective actions to input status of the recommendations directly into the computer network system.  This will eliminate mailing out the list of outstanding recommendations, written responses back to the Safety Department, and updating of the list by Safety and Health personnel.  This will result in status reports that are more current and closer to complete if not totally complete.
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