National Starch and Chemical Company Woodruff - Executive Summary |
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National Starch and Chemical Company makes products that are used in a variety of materials, including paper, packing materials, carpets, and even building products. The manufacture of these materials dictates that certain chemicals be used. Some of these chemicals are required to be addressed in a new EPA program, discussed below. The EPA Risk Management Program (RMP) is part of the Clean Air Act similar to what we have been doing for several years with the OSHA Process Safety Management (PSM) regulation. For the most part, the requirements are similar with one key difference. PSM is interested in accidents that could affect persons onsite. In contrast, RMP is interested in accidents that could affect persons offsite. The RMP program has three parts listed below. 1. Prevention Program (how to avoid accidents) 2. Emergency Response Program (how to handle an accident) 3. Hazard Assessment (what area might be impacted in an accident) REQUIREMENTS FOR WOODRUFF RMP regulations appl y to facilities that have certain chemicals in amounts exceeding a threshold quantity. The applicable chemicals at Woodruff are: - Acrylonitrile (toxic) - Ammonia (toxic) - Ethylene (flammable) - Vinyl Acetate (toxic) Specifics about each of these compounds are discussed in the section "Hazard Assessment". PREVENTION PROGRAM The Prevention Program is the first line of defense against accidents. The Prevention Program under RMP is essentially identical to that required by PSM. Thus, Woodruff has already been complying with this portion of RMP for several years. As implied by the name, the Prevention Program tries to avoid accidents. The Prevention Program consists of the following components and applies to the chemicals listed above. 1. Process Safety Information - maintaining physical details about the chemical processes such as toxicity and reactivity data, hazardous effects of inadvertent mixing, consequences of a deviation, process chemistry, design codes, and safety system s. 2. Process Hazard Analysis - Woodruff uses a Hazard and Operability Study (HAZOP) for the covered processes. The HAZOP covers hazards of the process, identification of potential accidents, engineering and administrative controls, consequences of failure of controls, siting, and human factors, and includes a qualitative evaluation of the health and safety impacts of control failure. At least one operator and one maintenance employee participate fully in the HAZOP. 3. Operating Procedures - specific instructions for the operators that includes information on startup, emergency shutdowns and other aspects of operation. 4. Training - new operators are trained on the operating procedures, health and safety hazards, emergency operations, and safe work practices. Refresher training is provided at least every three years. 5. Mechanical Integrity - applies to pressure vessels and storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. 6. M anagement of Change - Woodruff's Process Safety Review Committee (PSRC) reviews planned changes to operations or chemicals prior to the change. Changes are reviewed for the entire plant, not just for RMP- or PSM-covered projects. Changes are incorporated into the other Prevention Program sections. Woodruff is currently enhancing this program to be even more thorough. 7. Pre-Startup Review - when a change is big enough to change safety information during the Management of Change audit, a Pre-Startup Safety Review (PSSR) is required. Woodruff also may require these even when not required by law. The PSSR confirms that the requirements specified by the PSRC are met. An operator and maintenance employee are included in the PSSR. 8. Compliance Audits - the corporate Safety, Health and Environmental group audits the Prevention Program. 9. Incident Investigation - accidents are reviewed by the PSRC to determine if changes to equipment or operating practices are needed to prevent future accidents. 10. Employee Participation - PSRC must have an operator present at the meeting if a change involves an operator area, and PSRC meeting minutes are posted weekly for employee review. 11. Hot Work Permit - permits are issued for work that could potentially have an ignition source in flammable areas - the permits are used to ensure that proper safety precautions are in place. 12. Contractors - Woodruff has a contractor evaluation program in place to ensure that contractors meet safety requirements before working at Woodruff. Additionally, all contractors receive plant-specific training before starting work onsite. EMERGENCY RESPONSE PROGRAM In the event of an accident, an emergency response program minimizes the potential impact. Woodruff has internal response teams trained to handle many potential events and coordinates with local fire departments for backup or certain types of response. Woodruff has an onsite hazardous materials (HazMat) response team, and each member has at a minimum completed 40-hr technician training. Additionally, Woodruff has an onsite medical response team (First Responders) and a confined-space rescue team. Woodruff relies on the local fire departments for fire support and uses the Spartanburg County local emergency planning committee (LEPC) for backup for all events. Woodruff coordinates responses with the community responders through twice-yearly site drills. Woodruff is an active sponsor of both Enoree Fire and Rescue and the town of Woodruff fire department. HAZARD ASSESSMENT EPA requires that Woodruff estimate the potential impact zone for accidents involving the regulated chemicals. A computer model is used to estimate the potential impact distance. EPA requires that two cases be evaluated: a worst-case and a more realistic case. The worst-case is highly improbable. It involves the combination of a certain set of weather conditions (dawn after a clear, still night) with a release of the entire contents of the lar gest container of chemical with no intervention by plant employees. The weather conditions result in the vapor plume from the release staying very concentrated and narrow. The more realistic case uses typical weather conditions for the site (e.g., partly cloudy day or night with mild winds) and a more realistic accident. The result of the Hazard Assessment is a "zone of influence" which, for toxics, is a distance at which the air concentration of the chemical is at the EPA concentration limit. Nearly all individuals (including sensitive persons such as people with asthma) could be exposed to the EPA limit for up to one hour without irreversible or other serious health effects. EPA states the following about the EPA toxic limit (endpoint) and the worst-case analysis. "Because the assumptions required for the worst-case analysis are very conservative, the results likely will be very conservative. The endpoints specified for the regulated toxic substances are intended to be protect ive of the general public. These [toxic] endpoints are concentrations below which it is believed nearly all individuals could be exposed for one-half to one hour without any serious health effects. In addition, the worst-case analysis is carried out using very conservative assumptions about weather and release conditions. The distance to the endpoint estimated under worst-case conditions should not be considered a zone in which the public would likely be in danger; instead, it is intended to provide an estimate of the maximum possible area that might be affected in the unlikely event of catastrophic conditions. ... EPA intends the estimated distances to provide a basis for a discussion among the regulated community, emergency responders, and the public, rather than a basis for any specific actions." For flammables, the worst-case endpoint is a blast overpressure of one pound per square inch, which could cause partial collapse of houses and shattering of glass. The more realistic endpoint is the distance to the lower flammability limit (LFL), which is the lowest level at which a fire could burn. The scenarios to be reported to EPA and the zone of influence are listed for each chemical. Acrylonitrile Worst-case - storage tank total rupture - 0.8 miles More realistic case - spillage from truck unloading - 0.17 miles More realistic case - spillage from overfilling tank - 0.29 miles Ammonia Worst-case - storage tank total rupture - 0.3 miles More realistic case - not required due to short distance of worst-case Ethylene Worst-case - total rupture of bullets and liquid storage - 0.5 miles to 1 psi More realistic case - pressure gauge failure - 25 feet to LFL More realistic case - rupture disk opens - 100 feet to LFL More realistic case - total rupture of bullets and liquid storage - 250 feet to LFL Vinyl Acetate Worst-case - storage tank total rupture - 1.9 miles More realistic case - process line leak - 0.12 miles More realistic case - spillage from unloading - 0.09 miles WOODRUFF ACTIONS TO MINIMIZE HAZARD IMPACT Many factors can affect the hazard distance. At Woodruff, in addition to our Prevention Program and Emergency Response Program, we have taken the following steps to minimize the hazard distance. Spill Containment - our liquid tanks (acrylonitrile, ammonia, vinyl acetate) are all diked such that if a spill occurs, even a total rupture, the contents will stay inside the dike. This greatly reduces the potential impact distance. Storage Tank Volume - the larger the vessel size, the larger the potential impact. For this reason, we no longer receive railcar shipments of acrylonitrile (large container) and instead receive only truck shipments (small container). Mechanical Integrity - avoiding a spill in the first place is the best way to minimize the hazard distance. Recently, one ethylene bullet was removed from service and will be replaced with a new storage system after tests indicated the potential for weakened areas to devel op. Tank Location - The tanks and unloading areas are generally situated away from the main process areas and property boundary, such that if an accident were to occur the area of highest impact would be generally away from employees and the public. OTHER WOODRUFF ACTIONS The Woodruff plant is an active participant in the Responsible Care(r) program. Responsible Care(r) consists of 10 Guiding Principles and 6 Codes of Management Practices. The 10 Guiding Principles are listed below. 1. To seek and incorporate public input regarding our products and operations. 2. To provide chemicals that can be manufactured, transported, used and disposed safely. 3. To make health, safety, the environment and resource conservation critical considerations for all new and existing products and processes. 4. To provide information on health or environmental risks and pursue protective measures for employees, the public and other key stakeholders. 5. To work with customers, carriers, suppliers, distr ibutors and contractors to foster the safe use, transport and disposal of chemicals. 6. To operate our facilities in a manner that protects the environment and the health and safety of our employees and the public. 7. To support education and research on the health, safety and environmental effects of our products and processes. 8. To work with others to resolve problems associated with past handling and disposal practices. 9. To lead in the development of responsible laws, regulations and standards that safeguard the community, workplace and environment. 10. To practice Responsible Care(r) by encouraging and assisting others to adhere to these principles and practices. As you can see, we have already been following many requirements of the EPA program under Responsible Care(r). Woodruff is an active part of the community. We regularly have meetings with our Community Action Panel (CAP) to communicate openly with the community. On April 20, 1999, we participated with other Spartanb urg County industries in presenting RMP information through a public meeting in Spartanburg. It is important to stress that we are proactive in our efforts to prevent any incident from occurring. We are required to report this information by law. However, every day, in every way, we attempt to prevent, rather than react to situations which we imagine might possibly occur. |