Mobil Chemical Co. - Edison Research Laboratory - Executive Summary |
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Mobil Chemical Company Edison (NJ) Research Laboratory Risk Management Plan Executive Summary Background and Facility Description The Edison Research Laboratory (ERL) began in 1961 to develop improved products and new processes in support of Mobil Chemical plants around the world. Today, the laboratory performs advanced research into the newest generation of polyethylene resins used for various applications. Some of these test products are: plastic storage and trash bags; cast and laminated film for refrigerator and automobile components; thin films for packaging; and impact-resistant bottles, pails, and storage containers. One of the main operations at ERL is the Low Pressure Polyethylene Pilot Plant, which was started up in 1981. The pilot plant is used to scale-up laboratory research of advanced polyethylene resins, to meet the needs of consumers. The pilot plant plays a critical role in bridging the gap between laboratory research-scale studies and full-scale manufactu ring of new and improved products. The pilot plant handles ethylene, a material that is categorized as hazardous by the United States Environmental Protection Agency (USEPA) primarily due to its potential to cause a fire or explosion under certain conditions. The use of ethylene is regulated by recently- adopted accident-prevention regulations from both the USEPA and the New Jersey Department of Environmental Protection (NJDEP). ERL is a good corporate citizen and maintains a policy of operating in compliance with all applicable laws and regulations. ERL has precautions in place that include release-prevention safety devices combined with procedures and training that minimize the potential for onsite human exposure and for any offsite impact. Description of the Major Hazardous Substance and its Stationary Source Ethylene is received in tank trucks by ERL and is pumped as a very cold liquid into an insulated storage tank. If liquid ethylene leaks, it quickly turns into a gas. When it is mixed with a slight excess of air, ethylene will burn if it reaches an ignition source. But if it is mixed with exactly the right amount of air and reaches an ignition source, it will result in an explosion. If it does not contact an ignition source, it will spread into the atmosphere becoming harmless at a speed dependent on wind conditions. There have been no major releases of ethylene in the 18 years of pilot plant operation; however there have been two minor releases. On May 27, 1992, less than 1 pound of ethylene released over a 30-minute period due to a pinhole that developed in tubing near a pump. On April 11, 1986, less than 20 pounds of ethylene released over a 90-minute period during an unloading operation. In either minor release, there were no injuries and no impact to the surrounding community. Hazardous Assessment Results NJDEP and USEPA accident prevention regulations require companies to analyze for a worst case and an alternative release scenar io. For ERL, the worst case scenario as defined by the NJDEP and USEPA, is the sudden (ten minutes) release of all ethylene from the largest storage vessel at our facility after experiencing some type of catastrophic failure. We are also required to assume that the numerous safety and alarm systems as well as the explosion-proof electrical connections that we have in place, fail to operate as designed. We must also assume that this hypothetical release occurs during the least likely weather conditions to allow the wind to dissipate the vapor cloud; meaning very low wind speed and a stable, or stagnant atmosphere. This worst case scenario therefore assumes that three highly unlikely events as described below occur simultaneously: - Catastrophic failure of our ethylene storage tank; - All automated safety/alarm systems and explosion-proof connections fail to operate; and - The event occurs during stagnant meteorological conditions. While these events are highly unlikely, we are r equired to analyze such a release and to estimate the potential effect on the surrounding community. A release of this nature will not reach any buildings or homes beyond our fenceline. The alternative release scenario is intended to depict a potential release that theoretically has a greater possibility of occurring, but will likely have a less severe impact than the worst case scenario. ERL's alternative release scenario involves a hypothetical ethylene release from a gasket or hose during unloading of a tank trailer. Again, there are no off-site buildings or homes impact. Planned Changes to Improve Safety Edison Research Lab has created a culture that strives for continuous improvement of its safety program. Our lengthy participation as a STAR facility in the U. S. Occupational Safety and Health Administration (OSHA) Voluntary Protection Program (VPP) and the Chemical Manufacturers Association's Responsible Care Program encourages us to show such improvement every ye ar. Some examples of these planned changes are: - The Standard Operating Procedures in the Polyethylene pilot plant will be rewritten with more emphasis on the safety aspects and prevention of ethylene releases during each pertinent step involving the handling of this hazardous substance. - Continued review and resolution of safety recommendations identified in periodic hazard analyses, start up reviews, and accident or near-miss investigations. Prevention Programs Our Site Manager has the overall responsibility for ensuring that the facility operates in a safe and reliable manner. This responsibility includes overseeing the implementation of our risk management program (RMP). Our Site Manager has assigned the role of RMP Coordinator to a staff member who has the necessary background, training, and experience to develop and implement our risk management program. ERL has developed programs to comply with the industry's most stringent environmental, health, and safety stan dards. Our Edison facility adheres to the Chemical Manufacturers Association's mandatory Responsible Care. Program. Mobil Chemical was also the first company in the nation to have all of its facilities, including ERL, certified as STAR facilities in OSHA's VPP . STAR facilities are required to demonstrate exemplary safety performance and agree to work cooperatively with OSHA to serve as an example for other industry to follow. They are audited by OSHA for compliance every few years. ERL was the first research laboratory in the nation to earn the prestigious STAR recognition and has maintained it through five OSHA inspections over a fourteen year period. We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our process management systems address each of the key features of successful accident prevention programs including: - Process safety information - Pre-startup review - Process hazard analysis - Complia nce audits - Standard operating procedures - Accident investigation - Training - Employee participation - Mechanical integrity - Hot work permit - Management of change - Contractor safety These individual elements of our risk management program work together to prevent accidental chemical releases. In addition to our industry leading management programs, we have designed state-of-the-art systems and equipment to control, prevent, detect, and mitigate potential accidental releases. These systems include automated sensors and monitors designed to shutdown equipment in emergency situations and explosion-proof electrical connections. We employ extensive mechanical surveillance and preventive maintenance programs to ensure the integrity of our equipment and safety systems. The goal of these programs is to detect if the process equipment may be deteriorating and in need of repair or replacement, before failure occurs. This program also specifies the repairs (or parts replacement) needed to return equipment to acceptable specifications. We train our employees to safely perform their assigned tasks. Our training program includes initial training as well as periodic refresher training and training updates when major process or equipment changes are made. As part of our program, we include provisions for ensuring that employees understand the training, including written tests and field demonstrations. Emergency Preparedness and Response ERL has a fully developed emergency response plan detailing procedures to respond to accidental releases and other emergencies. We maintain a fully trained and equipped Emergency Squad on-site. Our plan is tested on a regular basis through joint exercises and drills with local, county, and state emergency response agencies. We maintain an "open door" policy with these organizations to help ensure maximum understanding and cooperation d uring an emergency. In the event of an emergency affecting our local community, ERL works closely with local, county, and state agencies to help ensure public safety. These agencies take the lead in informing the public on appropriate actions in the event of an emergency. Appropriate actions may include sheltering-in-place or evacuations. Sheltering-in-place would be recommended for those emergencies where it would be more prudent to remain in-doors than to be outside. Evacuations may be recommended for those emergencies of an on-going nature. In either case, notification would be made directly by local, county, or state officials. For additional information on what actions to take in the event of an emergency, contact the Edison Township Office of Emergency Management. |