Oxy Vinyls, LP - Louisville Facility - Executive Summary
The OxyVinyls Louisville Facility manufactures polyvinyl chloride (PVC) resin from polymerization of vinyl chloride. Oxy Vinyls, LP is a joint venture between Occidental Chemical Corporation (a subsidiary of Occidental Petroleum Corporation ) and The Geon Company. The facility is located on Bells Lane in Louisville, KY in an area known as "Rubbertown". |
LOUISVILLE FACILITY ENVIRONMENTAL POLICY
The Oxy Vinyls, LP Louisville Facility, a producer of Poly Vinyl Chloride Resins, is fully committed to conducting operations in a manner protective of the environment benefiting both our employees and community. We will accomplish this by:
7 Complying with all applicable federal, state and local regulations and permits.
7 Proactively finding ways to continually improve our environmental performance and prevent pollution through teamwork and innovation.
7 Utilizing The Chemical Manufacturers Association's Responsible Care. Initiative for clear guidance towards conducting our operations i
n an environmentally safe manner benefiting our employees and community.
7 Communicating this policy to all employees and other interested parties, and to manage its effective implementation through employee participation and the use of the Environmental Management System.
LOUISVILLE FACILITY SAFETY POLICY
The policy of the Louisville plant is to put its people's safety and health above all else. The philosophy that all accidents are preventable must be foremost in our minds as we make the multitude of decisions facing us each day. We must continue to remind ourselves that safety is NUMBER ONE on any list of priorities.
Oxy Vinyls, LP is committed to providing proper safety training and to maintain the Louisville plant as a safe facility in which to work. Each individual is expected to commit himself or herself to their own personal safety and to the safety of the Louisville plant.
Safety Is Both A Right And A Condition Of Employment.
SUMMARY OF REGULATED SUBSTANCES
Vinyls facility located in Louisville, Kentucky has one regulated flammable substance identified for the Accidental Release Prevention Program (40 CFR Part 68.130) above the Threshold Quantity (TQ) of 10,000 pounds: Vinyl Chloride Monomer "VCM" (CAS No. 75-01-4). No toxic chemicals listed in the Accidental Release Prevention Program exceed the TQ.
The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario, are outlined herein:
WORST-CASE RELEASE SCENARIO
Catastrophic failure of the South vinyl chloride storage tank (south sphere) would release 1,800,000 pounds of VCM. It is assumed that the entire contents of the south sphere is released as a vapor which finds an ignition source. Ten percent of the release quantity is assumed to participate in the resulting explosion. The distance to the endpoint of 1 psi for worst case scenario is 0.73 miles
Equation C-1 on page 92 of Offsite Consequence Analysis Guidance (OCAG) Document was used for estimation of the distance to the endpoint of 1 psi.
ALTERNATIVE RELEASE SCENARIO
A failure of the 2 inch hose connecting the rail car to the unloading apparatus. This release could be detected and isolated by active and passive safety systems in ten minutes or less and would result in a maximum release of 25,000 pounds of vinyl chloride over that ten minute period. For this scenario, the distance to a 1-psi overpressure would then be 0.06 miles for a vapor cloud explosion, per EPA's Offsite Consequence Analysis Guidance Document.
OxyVinyls has in place a prevention program encompassing elements consistent with the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM) for Highly Hazardous Chemicals (29 CFR 1910.119). VCM is regulated under the USEPA Clean Air Act Section 112(r)(7) Accidental Release Prevention Requirement
s: Risk Management Programs (RMP)(40 CFR Part 68) and the OSHA Process Safety Management Standard.
The OxyVinyls facility, which is covered under the PSM and RMP standards, has implemented the following:
1. An Employee Participation policy that requires regular consultation with employees regarding the development and implementation of PSM/RMP elements and hazard assessments.
2. A comprehensive Process Safety Information program, which insures complete and accurate written information concerning process chemicals, process technology and process equipment. This information is included in the employee training programs.
3. A program to conduct Process Hazard Analysis (PHA) to identify and analyze the potential hazards associated with the processing or handling of highly hazardous chemicals.
4. The preparation of Operating Procedures that describe tasks to be performed, operating conditions to be maintained, data to be recorded, and safety precautions to be taken.
5. Employee T
raining programs to insure that all employees, including maintenance and contract employees fully understand the potential hazards of each chemical. OxyVinyls has established an "Operator Certification" program to train, test and certify company employees.
6. Thorough evaluation of Contractors to insure that they have the appropriate job skills, knowledge and certifications to perform the job safely.
7. For new processes, a Pre-Startup Safety Review is conducted to insure a safe transition into the normal operating mode.
8. A Mechanical Integrity program to assure the integrity of process equipment. Elements include the following:
7 identification and categorization of equipment and instrumentation
7 inspections and test
7 establishment of prescribed inspection frequencies
7 development and application of pertinent maintenance procedures
7 training of maintenance personnel
7 documentation of test and inspection results
7 documentation of manufacturer's maintenance recommendati
9. A "Hot Work" Permit system is in place to manage welding, cutting or brazing of equipment in process areas.
10. A Management of Change system to properly manage changes involving processes, chemical, technology, equipment or facilities.
11. In the event of any chemical release or "near miss" a team of experienced individuals familiar with the process conducts an Incident Investigation. Any recommendations are documented within the Management of Change system.
12. An Emergency Response program for the entire facility and the surrounding community in the event of a chemical release.
13. Compliance Audits are performed to review all relevant documentation, verify process safety information, inspect the physical facilities and conduct interviews with representative plant personnel.
FIVE YEAR ACCIDENT HISTORY
During the past five years the OxyVinyls Louisville facility has not had any chemical releases which created an emergency situation outside the plant boundaries or res
ulted in any deaths, injuries, or significant property damage onsite or known offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage.
EMERGENCY RESPONSE PROGRAM
OxyVinyls Louisville facility has in place the following "Emergency Procedures" for handling accidental releases of chemicals:
7 Fire Emergency Procedure
7 Chemical Release Procedure
7 Facility Evacuation Procedure
7 Reporting Procedure
7 Medical Emergency Procedure
7 Natural Disaster Procedure
7 Spill Prevention Control and Countermeasure Plan
7 Emergency Coordination Plan
Plant personnel are trained in emergency procedures and emergency notifications. Trained personnel respond to emergencies in their area with the local Fire Department as a back up.
Coordinated drills with the Lake Dreamland Fire Department and the Local Emergency Planning Committee (LEPC) are conducted to insure good communication and operational effectiveness.
OxyVinyls participates in the Chemical Manufa
cturers Association's (CMA) Community Awareness Emergency Response (CAER) Code of Management practices.
OxyVinyls Louisville facility plans to continue to evaluate the regulated process as required under the PSM/RMP Standards to insure safe operations. Additionally, the company will continue to work with the local fire departments and LEPC to coordinate training drills and information.