Firestone Synthetic Rubber & Latex Co. Pilot Plant - Executive Summary |
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THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED The Firestone Synthetic Rubber and Latex Company facility in Akron is a small-scale experimental laboratory and pilot plant located on a 35-acre tract four miles south of Akron's downtown district. The plant is surrounded by light industry and residential areas. We develop new synthetic rubber products that will ultimately be manufactured on a commercial scale at our facilities in Texas and Louisiana. These products include styrene-butadiene and polybutadiene rubber used in vehicle tires, plastic modification, adhesives, asphalt modification, and other products. Each year, we pay about $155,000 in city and county taxes, $67,000 in State taxes, and buy about $1,350,000 in goods and services, mainly from local suppliers, paying about $550,000 for utilities and freight services. One of the chemicals we use as a raw material brings us under the EPA Risk Management Program (RMP) Rule. This is 1,3-butadiene, identified as a flammable substance under the RMP Rule. We have long had in place the types of accident prevention programs and emergency contingencies required by this new rule and continue to believe that effective safety and environmental practices are an integral aspect of sustainable business. THE ACCIDENTAL RELEASE PREVENTION PROGRAM AND EMERGENCY RESPONSE POLICIES AT THE STATIONARY SOURCE It is Firestone's policy to meet or exceed all safety, health and environmental regulations and industrial standards that apply to our facility. We put significant resources into compliance with the OSHA Process Safety Management Standard and related OSHA standards, and have expanded our programs to meet the specifics of the EPA RMP Rule. These programs help maintain extremely low levels of risk to our workers, contractors, the public, and the environment. This is achieved through a two-tier approach of defense-in-depth: (1) We minimize the possibility of a serious plant upset through proven engineering and procedura l safeguards. (2) We thoroughly plan contingencies in coordination with local responding agencies for the unlikely event of a serious accident. The success of our practices is reflected in our strong safety record to date. We have numerous other programs that address safety. For example, Firestone has in place an extensive Y2K program to evaluate and minimize risks to safety associated with Y2K issues as they relate to our computer systems and our suppliers' systems. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Our commitment of resources to our Process Safety Management (PSM) program is ongoing and we take pride in its success. The program is intended to prevent unwanted deviations from normal, daily operations, and to cope with any upsets in a way that will minimize the potential for harm within our facility fenceline and beyond. Recent examples of our investments in safety include: 1. a major project involving the replacement of older vessels to reduce further the chance of a leak of hazardous materials, at a cost of $350,000 2. relocation of butadiene storage vessels to reduce further the chance of an event that could impact the public or environment, at a cost of $500,000 3. a major upgrade of our Process Safety Management program, at a cost of more than $1 million. Firestone does not consider safety to be a stand-alone practice but, rather, a fundamental element of all aspects of our daily operations: No change is made in our process operations without going through a Management of Change procedure that systematically addresses and resolves any potential safety implications of the change. Preventive maintenance on pre-established frequencies is performed on all equipment that plays a role in the prevention or mitigation of process upsets to ensure that it is fully capable of meeting its design intent. Based on extensive written procedures, our personnel are trained, periodically retrained, and tested on the proper operation and maintenance of our facility, and on contingency actions under abnormal conditions. We conduct detailed, systematic process hazard analyses to identify what could hypothetically go wrong in the facility and, when warranted, make further plant or procedural improvements. Our equipment, instruments, and controls are designed for safety, complying with applicable regulatory and industry standards. Much of out facility is computer- controlled with operator back up, incorporating continual internal checks, emergency shutdowns, and alarms. Storage vessels at the facility are surrounded by concrete walls (dikes) in case of the unlikely event of a major chemical spill. Our process safety practices closely reflect the specific nature of the chemicals we use. This includes our operating procedures, maintenance procedures, process designs, and personal protective equipment. THE FIVE-YEAR ACCIDENT HISTORY We have had no events at the Firestone facility that would qualify for inclusion in the RMP 5- year accident history. THE EMERGENCY RESPONSE PROGRAM Our written emergency response plan is a set of detailed contingency procedures that are coordinated with the Summit County LEPC, the Akron Fire Department, and other local responders. We train all new personnel on the plan, conduct refresher training annually, and keep our personnel aware of any changes to the plan. Our emergency response plan complies with the RMP Rule and other applicable EPA and OSHA requirements. PLANNED CHANGES TO IMPROVE SAFETY Continuous safety improvement at our facility is achieved through day-to-day adherence to our Process Safety Management practices. Our program involves ongoing identification, analysis, and implementation of safety enhancement measures. THE WORST-CASE RELEASE SCENARIOS AND THE ALTERNATIVE RELEASE SCENARIOS Under the RMP Rule we have considered a worst case scenario (WCS). We believe this WCS to be extremely unlikely to occur. It involve s spontaneous, catastrophic failure of our largest storage vessel containing butadiene followed by a vapor cloud explosion. Based on use of the EPA Offsite Consequence Analysis Guidance, this scenario has offsite impact. A more credible scenario, called an alternative release scenario (ARS), was also analyzed. As required by the RMP Rule, we chose a hypothetical ARS that is severe enough to have effect beyond our fenceline. The selected ARS is highly unlikely, and guarded against by Firestone's Process Safety Management program. In this hypothetical ARS, the operator is pumping butadiene from a railcar to a storage tank when the transfer hose suddenly ruptures resulting in a spill. This scenario requires that a highly reliable safeguard fails: the excessive flow valve on the railcar that would cut-off the flow in the event of a hose rupture. The operator is assumed to take 5 minutes to shut off the flow after the hose rupture occurs. The released vapor is then assumed to ignite result ing in an explosion. Based on use of the EPA Guidance, the effects of the explosion are calculated to extend 121 yards, which is marginally beyond our fenceline, reaching our industrial neighbors, but not reaching the general public. The safeguards in place against this scenario are the excess flow valve on the railcar, along with a minimal likelihood of there being an ignition source present because of our adherence to National Fire Protection Association standards. A further precaution is that the hose would be pressure-tested before use, during which an imminent rupture (or, more realistically, a leak) would be expected to occur. This and similar scenarios will continue to be extremely unlikely because of our strong program of process safety. The results of this program have been acknowledged by awards we have received over the past several years from the Summit County Safety Council and the Ohio Division of Safety and Hygiene, recognizing accomplishments such as operating the enti re years of 1995 - 1997, achieving more than 1,000,000 manhours, without a lost-time injury. |