NOVA Chemicals Inc - Executive Summary |
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RMP Executive Summary The NOVA Chemicals Painesville site occupies 55 acres in Painesville, Ohio approximately 30miles east of Cleveland. The site is bordered on the north by a residential area, with Lake Erie approximately one-half mile to the north. The area south of the site is industrial. The nearest residence abuts our north property line. There are no schools or hospitals within three miles of the site. Currently, there are 58 NOVA employees working at the site, in manufacturing, technology and administrative jobs. The Painesville site is a national leader in the production of plastic resin for polystyrene foams. The major product is Dylite expandable polystyrene. The NOVA Chemicals Painesville site's approach to chemical safety is best described by the NOVA Chemicals Safety, Health, Environment and Risk Policy, which states that: NOVA Chemicals is committed to making protection of human health, safety and the environment its first priority. Protection and enhancement of the environment and the health and safety of employees, customers and the public form an integral part of all our business processes including: planning; research; facility acquisition, development and operation; product development; marketing; logistics; waste management; and decommissioning and divestiture of facilities. NOVA Chemicals readily accepts this life- cycle stewardship responsibility for all of its operations and will be a pace-setting company in its demonstrated performance. We operate on the premise that all accidents and incidents are preventable. We fulfill this policy commitment through the application of a comprehensive safety, health, environment and risk (SHER) management system which ensures that: Identifiable safety, health and environmental risks associated with NOVA Chemical's businesses, operations and products are assessed and successfully managed; Effective loss-prevention programs are in place and physical assets are protected; Safety, health an d environmental laws, regulations, and permit requirements are adhered to; Appropriate policies, programs and procedures are in place and continuous employee learning opportunities are available; Best available science, technology and industry practices are being applied with due consideration given to economics and technical practicality; Organizational responsibilities are clearly defined, understood and carried out and every employee is responsible and accountable for NOVA Chemicals' performance; Systems are in place to ensure that our SHER policies, standards and procedures are being followed and that performance is measured against the best in the industry; Change, whether it be in leadership, organization, chemical or business processes, is managed in a way that maintains, or if possible, enhances SHER performance; We only engage in business with companies that demonstrate a commitment to responsible SHER practices. NOVA Chemicals' SHER performance is communicated to all stakeholders. Excellence in SHER performance is everyone's responsibility. All employees must adopt and encourage safe work practices and conduct all work-related activities in an environmentally responsible manner. Leadership in all facilities and business units are accountable for their organization's SHER performance, and for achieving satisfactory performance from their customers, suppliers, carriers and contractors. NOVA Chemicals Painesville Site Process Description and Regulated Substances Used NOVA Chemicals Painesville Site is required to comply with the EPA 40 CR 68, Risk Management Program (RMP) because n-pentane is a listed chemical in the RMP and is used in our manufacturing processes in amounts above the threshold quantity (TQ). Pentane is used to produce expandable polystyrene resin (EPS) which is manufactured at the Painesville Site. Our resin is in bead form and is sent to customers who turn the beads into end products, such as packaging or insulating material s. Pentane is piped through a closed system from a 40,000-gallon storage tank into the vessels in the process area. Pentane is used during two parts of the process, initially during bead formation then later during the drying stage as a paste applied to the beads to provide lubrication during our customers processing. Pentane is brought on site in 36,000-gallon rail cars. Pentane vapors are collected during the process in a spherical gas ball and sent to the boiler for destruction. Worst-case release scenarios EPA has defined a worst case release as the release of the largest quantity of a regulated substance that results in the greatest distance from the point of release to a specified end point. At the Painesville site, the only regulated substance that is used is n-pentane, which is a flammable substance. The EPA recently changed the Worst-Case release scenario requirement for flammables that are liquids at ambient temperatures. This change allowed for a more realistic release scenario, where the tank holding the largest amount of the flammable substance fails, causing the entire contents to pool into the surrounding dike. The amount that becomes vapor in the first 10 minutes of the release is used to determine the endpoint during a vapor cloud explosion. Applying the worst-case scenario definitions at Painesville, the following information was derived: Worst -Case Scenario: Worst-case scenario involves a release of the maximum quantity of n-pentane (208,000 lbs.) contained in the pentane storage tank. This would result in a vapor cloud containing 4200 pounds of n-pentane vapor within the first 10 minutes of the release. The release of this amount of n-pentane, coupled with a vapor cloud explosion, would result in a 1 pound per square in. (psi) overpressure at an end point of .13 miles. EPA's OCA Guidance Reference Tables and Equations was the modeling used to determine this overpressure end point. This endpoint contains no residential receptors but does cross onto the industrial property directly south of the plant. Alternative Release Case Scenario The processes involving n-pentane at the site were studied to develop the alternate case scenario. Utilizing the knowledge of the operators and the Process Engineer, an alternate case scenario was developed that would have a greater likelihood of occurring. This scenario involves the failure of a 4-inch railcar unloading hose. The area where this would occur has a passive mitigation system consisting of drainage to a gravel dike area where it is possible a vapor cloud fire may occur. The scenario involved active and passive mitigation, involved a release of approximately 157,500 pounds of n-pentane with an RMPComp estimated distance to end point of .06 miles. This scenario does not involve any off site consequences. A more likely scenario involving off site consequences could not be found. Accidental Release Prevention Programs To prevent the situations described above from oc curring, these processes are covered under OSHA Process Safety Management (PSM) rule, OSHA 1910.119. All 14 elements required under the PSM rule are in place at the site and have been integrated into the prevention plan requirements under the Risk Management Program. Compliance with the PSM rule provides the foundation for compliance with the Risk Management Program. Some of the specific prevention measures in place include the following: * There are pressure relief systems on the storage tanks. * Dikes surround the storage tanks. * There are on going equipment inspection programs in place to monitor mechanical integrity. * The tanks are protected by firewater deluge systems. * Area classifications are required to guard against the introduction of ignition sources into the processes. * There are hydrocarbon sensors and alarms in the area to detect pentane releases. * The site's operation technicians continuously monitor pentane-unloading operations. There have been no accide nts at the Painesville site involving n-pentane in the last 5 years. In fact, pentane has been used at the site for more than 15 years without any major off-site incidents. To further improve site safety and emergency preparedness, the Painesville Site coordinates its emergency response plan with the Lake County Local Emergency Response Committee (LEPC). The site conducts bi-annual training emergency response drills in conjunction with the LEPC and the local fire department. And the site SHER Specialist maintains close communication with the Lake County LEPC coordinator on a regular basis. The next series of site process hazard reviews will begin in 2001. These reviews are required by PSM every 5 years, our last review was in 1996. In addition to PHA's required by OSHA, there is an annual Responsible Care audit performed by internal NOVA Chemicals auditors, as well as a Loss Prevention audit. Additional focus will be placed on our pentane storage and handling methods during these r eviews to determine if additional safeguards should be added to our current Painesville site programs. |