Flexsys America L.P. - Executive Summary

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The Flexsys America L.P. (FLEXSYS) Monongahela, Pennsylvania facility, is located in a rural area outside of the town of Monongahela. Chemical production has occurred at the site since 1916, originally operating as the Stauffer Chemical Company. 
FLEXSYS is the world's leading producer of chemicals for the rubber processing and related industries. FLEXSYS products go into the production of rubber tires and other rubber articles.  In June 1998, FLEXSYS was one of only six companies to receive the 1998 Presidential Green Chemistry Challenge Award. The award, which honors organizations that successfully research, develop and implement outstanding green chemical technologies, was presented at the National Academy of Sciences in Washington DC.  
Our workforce is comprised of production, maintenance, engineering, technical, clerical, and management personnel.  The average level of chemical plant experience for our employees exceeds 15 years.  We are proud of our facility and the stability of 
our workforce. 
The Federal Accidental Release Prevention Requirements under the Clean Air Act Section 112(r), codified in 40 CFR Part 68, were written to help prevent the accidental release of extremely hazardous substances and to minimize the consequences of any such release.  All facilities with threshold quantities (TQs) of the listed regulated acutely toxic and flammable substances are subject to these provisions.  The listed substances include 77 toxic chemicals with TQs ranging from 500 lbs. to 20,000 lbs., while the 63 flammable substances all have a TQ of 10,000 lbs.  FLEXSYS has one chemical, carbon disulfide (CS2), that meets the toxic chemicals TQs, and thus, this substance must be included in a Risk Management Program for its use within a process. 
CS2 is a yellowish liquid with an unpleasant odor. In nature, very small amounts are found in gases from volcanic eruptions and in marshy areas. CS2 has been an important industrial chemical since the 1800s because of its many  
useful properties, including its ability to solubilize fats, rubbers, phosphorus, sulfur, and other elements. CS2 has been highly suitable for other industrial applications including the vulcanization and manufacture of rubber and rubber accessories; the production of resins, plywood adhesives, and flotation agents; petroleum-well cleaning; brightening of precious metals in electroplating; rust removal from metals; and removal and recovery of metals and other elements from wastewater and other media. In agriculture, CS2 was formerly widely used as a fumigant to control insects in stored grain.  
The major Clean Air Act Section 112(r) ("112(r)") requirements with which FLEXSYS must comply for use of CS2 include: 
  - Management System development and documentation, 
  - Hazard Assessment for each affected process, 
  - Prevention Program completion, 
  - Emergency Response Program coordination, and 
  - Risk Management Plan submittal.   
In addition, FLEXSYS recognizes its responsibili 
ty under Section 112(r)(1) (the "general duty clause") to handle all Extremely Hazardous Substances safely and to identify hazards that may result from accidental releases.  Furthermore, FLEXSYS works to prevent accidental releases and to minimize the consequences if a release occurs.  Additional chemicals on site, not meeting their TQ or not identified in the 112(r) list rule, include hydrogen sulfide and small quantities of chemicals used in laboratory analysis.  These "general duty" chemicals are managed using the sound risk-management principals applied to our chemical fully covered by 112(r).  FLEXSYS follows a prevention program including the use of process safety information, operating procedures, employee training, mechanical integrity, management of change, pre-startup review, incident investigation, compliance audits, "hot work" by permit only, and evaluation of contractors. 
This Executive Summary to the FLEXSYS Risk Management Plan (RMP) provides an overview of how we are e 
ffectively meeting our responsibilities to the community through compliance with 112(r) requirements. 
    FLEXSYS has established a management system to oversee the implementation of its Risk Management   
    Program responsibilities.  The management system is designed to help ensure that each element of our 
    program is fully and effectively completed.  A qualified engineer has been assigned overall  
    responsibility for the development, implementation, and integration of the program elements.   
    Responsibility for implementing individual requirements of FLEXSYS' program have been delegated to 
    competent individuals.  An organization chart has been prepared to identify the responsible personnel  
    and lines of authority for implementing the program.  Record-keeping responsibilities are also included in 
    the management system. 
    FLEXSYS fully supports the ideals and efforts of its Risk Management Program management system. 
    The Hazard Assessment portion of the 112(r) rule requires facility owners or operators to prepare  
    "worst-case" and "alternative" release scenarios as appropriate to the operations.  From the release  
    scenarios, facilities are then to determine offsite impacts using specified "Offsite Consequence  
    Analysis" parameters for worst-case releases and more realistic parameters for alternative releases. 
    As defined by the U.S. Environmental Protection Agency (EPA): 
       - The worst-case release involves the release of the largest quantity of a listed toxic substance that 
          is estimated to generate the greatest distance in any direction to a toxic endpoint defined in the  
         112(r) regulation.  The probability that a worst-case release might occur or the possible causes of 
         such a release are not considered. 
       - The alternative scenario involves an accidental release that is "more likely to occur" than the worst- 
         case re 
lease scenario.  Scenarios to consider include transfer hose splits or uncoupling, process  
         piping failures, process vessel or pump cracks and failures, vessel overfilling and spill or  
         overpressurization and venting through relief valves or rupture disks, and shipping container  
         mishandling and breakage or puncturing leading to a spill. 
    FLEXSYS prepared worst-case release scenario analyses and alternative release scenario analyses  
    for CS2, based on requirements given in the 112(r) rule. 
    Worst-Case Release Scenario: 
       7 A rupture of a single 50 ton railcar and subsequent unmitigated release of its CS2 contents. 
    Note, the railcar is off-loaded only once a year.  In addition, work is underway to mitigate a potential spill 
    at the railcar off-loading area. 
    Alternative Release Scenario: 
       7 CS2 is discharged from a 3" process pipe due to a gasket rupture, but the amount released is limited  
         by operator  
    The Offsite Consequence Analysis of the chemical release was analyzed using appropriate air  
    dispersion analysis and modeling techniques.  Air dispersion modeling is the use of a computer to 
    simulate the spread of air pollutants.  Dispersion modeling can be used to determine the movement and  
    concentration of toxic gases emitted from an accidental release.  In both the worst-case and alternative 
    Offsite Consequence Analysis modeling cases, "worst-case" weather conditions were used to  
    simulate poor dispersion of the chemical, even though the 112(r) rule allows the use of more favorable 
    dispersion conditions, such as increased wind speeds and a greater dilution factor, for the Alternative  
    Release Scenario analysis. The topography surrounding the FLEXSYS operations will frequently  
    contribute to poor dispersion conditions, especially at night and through early morning. Therefore, use  
    of "worst-case" meteorology is prudent. 
 To determine the Offsite Consequence Analysis of worst-case and alternative releases of CS2,  
    FLEXSYS used the most-recent version of several air dispersion models and modeling techniques, as  
       RMP*Comp is based on the U.S. EPA's RMP Offsite Consequence Analysis Guidance (May 1996).   
       This guidance document provides rough estimates of offsite impacts from evaporating pools of 
       chemicals and vapor clouds. 
       ALOHA (Areal Locations of Hazardous Atmospheres) dispersion model, developed by the National  
       Oceanic and Atmospheric Administration and the EPA, incorporates specific chemical release  
       characteristics that provide somewhat more refined estimates of offsite impacts from a variety of  
       chemical releases.  ALOHA is part of the CAMEO (Computer-Aided Management of Emergency  
       Operations) system used by many emergency response teams. 
       SLAB, developed by the Lawrence Livermore National Laboratory, is a 
n EPA-recommended dense- 
       gas model that provides more refined estimates of offsite impacts from heavier-than-air chemical  
    Should an accidental release occur that has potential for offsite consequences, plant-wide alarms will  
    sound.  The emergency response team will provide an immediate and rapid response and emergency  
    shutdown systems and procedures will be activated. 
    Modeling Limitations and Assumptions 
    Air-dispersion models are limited in their ability to accurately predict the impact of a chemical release.   
    Their limitations increase as the complexity of the topography surrounding the release site increases.   
    The EPA-recommended models used for the FLEXSYS worst-case and alternative release scenarios  
    have likely over-estimated the impact distance, because of several complicating conditions: 
       7 Surrounding the CS2 railcars, storage tanks, reactor vessel, and piping are large industrial buildings  
    and structures.  These features disrupt and redirect air flow, but the models used assume winds  
         are steady and moving in a straight line. 
       7 Beyond plant property, buildings, structures, vegetation, and terrain features also serve to disrupt  
         and redirect airflow. 
       7 The chemical emitted is assumed to have no reaction with the ground, other chemicals, or other  
         potential release conditions. However, it is likely that a release of CS2 will deposit on the ground and  
         other surfaces as it disperses from a ground-level source.  In addition, because of an auto ignition     
         temperature, CS2 will likely ignite.  In each case, the resulting impact distance is likely to be less than  
         the distance predicted by the models. 
    Note that a "synergistic effect" can occur from two chemicals interacting during an accidental release.  
    Such synergism results when the effect of two substances acting together "is gre 
ater than the sum of 
    their individual effects."  No synergistic reaction is expected with respect to CS2. 
    The Prevention Program ensures that regulated substances are safely stored, used, and handled.  In  
    addition, if a chemical release occurs, the Prevention Program ensures that procedures and equipment  
    are established to detect and mitigate the impact of such a release. The completion of Occupational  
    Safety and Health Administration (OSHA) Process Safety Management (PSM) requirements essentially  
    satisfies the 112(r) Prevention Program requirements for CS2 in the Program-level 3 processes. 
    Safeguarding the public from accidental releases through an effective Prevention Program is an  
    important component of the 112(r) rule.  FLEXSYS has been diligent in its completion of the Program 3  
    Prevention Program requirements for: 
       7 Process safety information: FLEXSYS compiled written process safety information 
that is completed 
         prior to conducting any process hazard analysis required by the rule.  This written information  
         enables FLEXSYS and the employees involved in operating the process to identify and understand  
         the hazards posed by those processes involving regulated substances.  Minimum information  
         includes hazards data such as that found on a Material Safety Data Sheet, technology information,  
         and equipment information. 
       7 Process hazard analysis:  A hazard evaluation has been performed by an experienced team to 
         identify, assess, and control the hazards involved in each of the covered areas.  The HAZOP and  
        "what-if" methodologies were used for determining and evaluating the hazards of the process.  The  
         analysis addressed the hazards of the process, the identification of any previous incident which  
         had a likely potential for catastrophic consequences, engineering and administrative c 
         applicable to the hazards and their interrelationships such as appropriate application of detection  
         methodologies to provide early warning of releases, consequences of failure of engineering and  
         administrative controls, stationary source siting, human factors, and a qualitative evaluation of a  
         range of possible safety and health effects of failure of controls. These analyses are being updated  
         and revalidated on a five year basis. 
      7 Operating procedures: Written procedures have been developed and implemented to provide clear  
        instructions for safely conducting activities involved in each covered process consistent with the 
        process safety information.  Elements that are addressed include steps for each operating phase,  
        operating limits, safety and health considerations, and safety systems and their functions.  Operating  
        procedures are readily accessible to employees who work in or 
maintain a process.  These  
        procedures are reviewed as often as necessary to assure they represent current operating  
        practice.  Annual certification helps to assure the currency and accuracy of the procedures.  In  
        addition, safe work practices, applicable to employees and contractor employees, are developed and 
        implemented to provide for the control of hazards during a variety of plant operations. 
      7 Training:  Initial and refresher training is conducted as appropriate for each employee involved in  
        operating a process.  FLEXSYS ascertains and documents that each employee has received and  
        understood the required training. 
      7 Mechanical integrity:  FLEXSYS has developed a comprehensive mechanical integrity program that  
        applies to pressure vessels and storage tanks, piping systems, relief and vent systems and devices,  
        emergency shutdown systems, controls, and pumps in the covered processes.  Writt 
en procedures,  
        training for process maintenance activities, inspection and testing, correction of equipment  
       deficiencies, and quality assurance are all included in FLEXSYS' mechanical integrity program. 
      7 Management of change:  Written procedures have been established and implemented to manage  
        changes (except for "replacements in kind") to process chemicals, technology, equipment, and  
        procedures; and changes to other stationary sources that affect a covered process.  The  
        procedures assure that the technical basis for the proposed change, the impact of the change on the 
        environment, safety, and health, the modifications to operating procedures, the necessary time  
        period for the change, and authorization requirements for the proposed change are all addressed.  
        Appropriate employees and contractors are informed of, and trained in, the change prior to startup of  
        the process or affected part of th 
e process. Updates to the RMP are made if required by the nature of 
        the change. 
      7 Pre-startup review:  A pre-startup safety review is performed for new covered processes and for  
        significantly modified covered processes at FLEXSYS.  Such review confirms that prior to  
        introduction of regulated substances to the process that construction and equipment is in  
        accordance with design specifications; safety, operating, maintenance, and emergency procedures 
        are in place and adequate; for new stationary sources, a process hazard analysis has been  
        performed and for modified stationary sources, management of change requirements have been met; 
        and training of each employee involved in operating a process has been completed. 
      7 Compliance audits:  FLEXSYS evaluates compliance with the provisions of this section at least every  
        three years to verify that the procedures and practices developed under the standard 
are adequate  
        and are being followed.  FLEXSYS' compliance audit is conducted by a team consisting of outside  
        auditors, the Manager of Safety & Training and representatives from each covered process.  A  
        report of the compliance audit findings is developed.  FLEXSYS promptly determines and documents  
        an appropriate response to each of the audit findings, establishes a schedule for acting on the  
        findings and documents that deficiencies have been corrected.  The two most recent audit reports  
        are retained. 
      7 Incident investigation: FLEXSYS will investigate each incident that results in, or could reasonably  
        result in a catastrophic release of a regulated substance.  This investigation shall be initiated as  
        promptly as possible, but not later than 48 hours following the incident.  An incident investigation  
        team will be established with appropriate personnel.  A report, which shall be retained for 
five years,  
        is prepared at the conclusion of the investigation.  A system has been established to promptly  
       address and resolve the findings and recommendations of the incident report, with documentation of  
       resolutions and corrective actions.  The report shall be reviewed with all affected personnel,  
       including contract employees where applicable, whose job tasks are relevant to the incident findings. 
     7 Employee participation:  FLEXSYS has developed a written plan of action regarding employee  
       participation.  Employees and their representatives are consulted with on the conduct and  
       development of process hazards analyses and on the development of the other elements of process  
       safety management in the 112(r) rule.  Employees and their representatives are also provided access 
       to process hazard analyses and to all other information required to be developed under the rule. 
     7 Hot-work permit:  FLEXSYS issues 
a hot-work permit for hot-work operations conducted on or near a 
       covered process.  The permit documents that the fire prevention and protection requirements in 29  
       CFR 1910.252(a) have been implemented prior to beginning the hot-work operations.  The permit  
       further indicates the date(s) authorized for hot work and identify the object on which the hot work is 
       to be performed. The permit is kept on file until the hot-work operations is completed. 
     7 Contractors:  FLEXSYS and contract-company owners and operators comply with the requirements  
       for contractors performing maintenance or repair, turnaround, major renovation, or specialty work on  
       or adjacent to a covered process. Contractor issues include, among other responsibilities, evaluation  
       of past contractor safety performance and programs, and informing contractors of known potential  
       fire, explosion, or toxic release hazards related to the contractor's work and  
the affected processes. 
       (Note that this part of the RMP requirements does not apply to contractors providing incidental  
       services that do not influence process safety, such as janitorial work, food and drink services,  
       laundry, delivery or other supply services.) 
    In summary, FLEXSYS is prepared to prevent and mitigate accidental releases by safe process and  
    equipment design, maintenance of equipment, operating safely, and auditing our operations. 
       7 Process and Equipment Design:  Backup safety systems, pressure relief valves venting to the flare  
         stack, insulated vessels and piping, local emergency shut down system, and a reservoir system for  
         the storage of CS2 tanks, are used to help mitigate the potential for leaks from the affected  
         processes and equipment. 
       7 Equipment Maintenance:  FLEXSYS has a preventive maintenance program in place along with work 
         planning, safety checks and reviews, per 
iodic inspections, and qualified maintenance personnel. 
       7 Safe Operations: Operators are trained and certified.  Operations are continuously monitored by  
         the operator and computer. Written procedures are in place and followed by operators. 
       7 Operations Auditing:  Internal and Independent audits of the CS2 operation are performed. 
    For at least the past five years, no accidental releases from covered processes have occurred that  
    resulted in deaths, injuries, or significant property damage onsite or known offsite, deaths, injuries,  
    evacuations, sheltering in place, property damage, or environmental damage. 
    An Emergency Response Program has been developed and was implemented as required for the  
    purpose of protecting public health and the environment. 
    In-plant emergency response consists of training and planning to prepare for, prevent, respond to, and  
    recover from em 
ergencies.  Those situations identified include hazardous material releases, fire,  
    explosion, floods, severe weather, and terrorism.  A plant specific incident command system has been  
    installed.  This system is designed to be used for all types of emergencies, and is applicable to both  
    small releases or minor fires and large-scale disasters.  A chain-of-command and assigned  
    responsibilities have been established within this system in order to assess and respond to emergency  
    situations.  Plant-wide alarms are activated in the event of an emergency. 
    In addition to in-plant emergency response events, a system has been established in order to notify  
    outside personnel.  Depending on the severity and type of event, facilities/agencies notified include, but  
    are not limited to, local police, fire and ambulance service, Local Emergency Planning Committee of  
    Washington County, Pennsylvania Emergency Management Agency (PEMA), and the Pennsylva 
    Department of Environmental Protection (Pittsburgh). 
    Work is underway to construct a dike at the railcar off-loading area, although, as reported above, the  
    railcar is off-loaded only once a year.  In other areas of the plant, instrumentation has been added to  
    the emergency flare stack to assure that all three pilots are burning.  Also, only a limited quantity of CS2  
    is typically contained in the processes' reactor vessel, thus reducing the amount that could potentially  
    be released during an accident involving this unit. 
    FLEXSYS has an ongoing program to evaluate and upgrade its safety systems.
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