The Geon Company Avon lake Facility - Executive Summary

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THE GEON COMPANY 
 
ENVIRONMENTAL POLICY 
 
It is the policy of the Geon Company to conduct our operations in a manner fully protective of 
employees, customers, public health and the environment. Implementation of this policy shall be through programs which are proactive in nature and go beyond compliance with applicable laws and regulations Geon's commitment to the principles of Responsible Care provides clear guidance for action.  We will conduct ongoing evaluation of our operations and products to identify practical opportunities for contInuing reduction of releases and wastes. We are committed to a continued reduction of emissions and permit exceedances, as well as, minimizing the generation of solid and hazardous waste.  Excellence in program leadership and stewardship is a key management responsibility. Insuring that all operations in the company are carried out in accordance with this Policy is the responsibility of each employee. 
 
SAFETY AND HEALTH POLICY 
 
The policy of our Company 
is to safeguard the health and well-being of each employee and our 
neighbors. Implementation of this policy shall be through the elimination of accidents and by establishing through our activities safety and health management among the highest corporate priorities. This policy applies to all employees and contractors to the GEON Company. 
Ensuring the safety of all personnel is everyone's concern and requires a constant sense of awareness and attention to detail. The development of safety awareness can only come through each person's acceptance of his responsibility for safety in conjunction with adequate job orientation, training, recognition and communication of the hazards associated with each work situation. Everyone must believe that all accidents are either preventable or avoidable. 
Effective management of our process safety is critical in maintaining the integrity of our operations. All necessary equipment, tools, technologies, procedures, and training will be provided to assist 
everyone in operating our processes and performing their jobs safely. At GEON every job and operation must be managed safely.  Safety performance will be a key element of each employee's and contractor's performance evaluation.  Excellence in safety performance is a condition of employment at GEON.  The prevention of accidents while off the job is equally important. The same principles at work are also effective in preventing accidents in the home, on the highway and in all other activities. 
 
Working and living safely must be our way of life.  
W.F. Patient 
Chairman of the Board 
President & CEO 
 
 
SUMMARY OF REGULATED SUBSTANCES 
 
The GEON Company, located in Avon Lake, Ohio, 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.  
 
 
RELEASE S 
CENARIOS 
 
The worst-case release scenario(s) and the alternative scenario(s), including administrative controls 
and mitigation measures to limit the distance for each reported scenario are outlined herein: 
 
WORST-CASE RELEASE SCENARIO 
 
Failure of the tandem pair of storage tanks would release 210,000 pounds of VCM. It is assumed that the entire contents of the two adjoined tanks are released as a vapor which finds an ignition source. 10% of the release quantity is assumed to participate in the resulting explosion.  The distance to the endpoint of 1 psi is 0.355 mile with the distance for radiant heat dose of 5 kW/square meter of 0.347 for the worst case scenario.  
 
Using the equations for calculating over pressure from the RMP Offsite Consequence Analysis Guidance Document (OCAG). 
' The endpoint for VCM is 0.355 mile (1875 feet). 
 
Using Fire Radiation Table 22, Page 68 of OCAG. 
' Endpoint for VCM is 0.347 miles (1832 feet). 
 
 
ALTERNATIVE RELEASE SCENARIO 
 
A failure of the hose connecti 
ng a rail car to the unloading apparatus. The excess flow valve(s) function to limit the flow. The entire contents of the tank car, 180,000 pounds of VCM are released in 3.5 hours. Unconfined vapor travels to the lower flammability limit(LFL).  
 
The distance to the endpoint for the LFL for the alternative scenario is less than 317 feet. 
 
Using Exhibit C-2, page 98 of OCAG.  
' LFL of VCM is 92 mg/l  
 
Using Reference Table 21, Page 65 of OCAG. 
' Distance to LFL for 1,000 pound/minute release rate is <0.06 mile. (317 feet) 
 
PREVENTION PROGRAM 
 
The Geon Company 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, the same substance is regulated under the USEPA Clean Air Act( Section1 12(r)(7)Accidental Release Prevention Requirements: Risk Management Programs(RMP)( 40 CFR Part 68).  
 
The GEON facility which is covered unde 
r the PSM and RMP standards has implemented the following:     
 
1. An Employee Participation policy has been instituted to regularly consult 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. Process Hazard Analysis (PHA) is conducted to identify and analyze the potential hazards associated with the processing or handling of highly hazardous chemicals. 
 
4. The preparation of Operating Procedures which describe tasks to be performed, operating conditions to be maintained, data to be recorded, and safety precautions to be taken.  
 
5. The GEON Company has established Employee Training programs to insure that all employees, including maintenance and contractor employees involved with chemical 
s fully understand the potential hazards of each chemical. The GEON Company has established an "Operator Certification" program to train, test and certify company employees.  
 
6. Contractors are thoroughly evaluated 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 is in place to assure the integrity of process equipment. Elements include the following:  
 
' Identification and categorization of equipment and instrumentation  
' Inspections and tests 
' Establishment of prescribed inspection frequencies  
' Development and application of pertinent maintenance procedures  
' Training of maintenance personnel  
' Documentation of test and inspection results  
' Documentation of manufacturer's maintenance recommendations 
 
9. A "Hot Work" Permit system is in place to manage weldin 
g, cutting, brazing or spark producing operations in process areas. 
 
10. To properly manage changes involving processes, chemicals, technology, equipment or facilities a Management of Change system has been implemented..  
 
11. In the event of any chemical release or "near miss" an Incident Investigation is conducted by a team of experienced individuals familiar with the process. Any recommendations are documented within the Management of Change system.  
 
12. An Emergency Response program is in place 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 ACCIDENTHISTORY 
 
During the past five years the GEON Company has had no chemical releases which created an emergency situation outside the plant boundaries nor resulted in any deaths injur 
ies, or significant property damage on site or known offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage.  
 
 
EMERGENCY RESPONSE PROGRAM 
 
The Geon Company has in place the following "Emergency Procedures" for handling accidental releases of chemicals: 
 
' Fire Emergency Procedure 
' Chemical Release Procedure 
' Facility Evacuation Procedure 
' Notification of Key Personnel Procedure 
' OSHA Vinyl Chloride Monomer Standard 
' Spill Prevention Control and Countermeasure Plan 
 
A thorough notification system is in place to initiate response to any emergency. Key personnel are notified by a system of pagers and alarms. Once this notification system is activated, a series of emergency plans is followed by key personnel. For example, in the event of a fire, the Emergency Response Team will respond and an onsite Chain of Command communication system is implemented. The Emergency Response Team is trained to deal with chemical releases and emergencies.   
The Emergency Response Team conducts regular training sessions for team members. All members are trained in First Aid/CPR.  Coordinated drills with the Avon Lake Fire Department and the Local Emergency Planning Committee(LEPC) are conducted to insure good communication and operational effectiveness.  
 
The Geon Company participates in the Chemical Manufacturers Association's (CMA) Community Awareness Emergency Response(CAER) Code of Management practices.  
 
 
FACILITY IMPROVEMENTS 
 
The Geon Company 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. The GEON Company annually performs a complete facility review to verify an effective Environmental, Safety and Health program.
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