Ameripol Synpol Corporation - Port Neches Plant - Executive Summary |
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Ameripol Synpol Corporation's Port Neches Plant is a Styrene Butadiene Rubber (SBR) manufacturing facility employing nearly 700 people who live and work in the Port Neches, Texas area. In business at the same location since 1943, ASC is a quality producer of synthetic rubber that is used in the manufacture of automobile tires, shoe soles and a wide array of rubber product. The ASC Port Neches SBR facility receives butadiene by pipeline and styrene by barge. These products are combined in reactors to produce latex. Unreacted butadiene and styrene are then recovered and recycled. Resulting latex stock is coagulated (at which point it is referred to as rubber), after which it is washed and dewatered. The rubber is then broken into small pieces (referred to as crumb rubber), and dried prior to packaging. ASC is dedicated to protecting its employees, the community, and the environment from chemical incidents through safely operating the facility. Our corporate policy has established as a principal objective that accidents must be prevented by every reasonable means available. It is our philosophy that there is no conflict between safety, quality, and productivity. Sound safety practice at all times will in the long run enhance, not impede, quality and production. Each employee shares in the responsibility for complying with ASC policies and practices related to safety as a condition of employment. The Environmental Protection Agency (EPA) requires certain companies, like ASC, to develop and share information about the chemicals we use, the potential risks those chemicals pose to the community, the many ways that we manage those risks, and in the unlikely event of a release, how well we are prepared to respond to that situation. This requirement is part of the EPA's Risk Management Planning (RMP) rule. The rule requires companies that use or store certain threshold quantities of toxic or flammable chemicals to develop scenarios that estimate the potential co mmunity impact from an accidental release. Ameripol Synpol Corporation currently has two chemicals in threshold quantities affected by the rule - ammonia (due to its toxicity), and 1,3-butadiene (due to is flammability). Butadiene (BD) is primarily used in the production of rubber, while ammonia is used as a refrigerant within the rubber production process. The facility typically maintains an average of 1,000,000 pounds (lbs) of BD and 75,000 lbs of ammonia onsite. There are fourteen (14) units and several process areas to which RMP applies at the facility because of BD content: 7 ten Reactor Units [N8A, S8A, N8B, S8B, 8CA, 8CB, 8CC (Continuous), 8CC (Batch), 8DA and 8DB], 7 four Recovery Units (7A, 7B, 7C/CC and 7D), as well as 7 the Tank Farm, and 7 the Pipe Rack and Flare system. The Refrigeration Unit and the Compressor House are covered by RMP as a result of ammonia handling. ASC is also required to compile an accident history for the RMP listed chemicals at the faci lity for the past five years. According to the RMP rule, an accidental release from a facility regulated by RMP is defined as one that resulted in death, injuries, significant property damage, evacuations, shelter-in-place, or environmental damage. There have been no accidental releases at facilities regulated by RMP at ASC Port Neches Plant during the past five years. The Port Neches Plant has several policies in place to prevent accidental releases, as well as policies to respond to emergencies. These policies include, but are not limited to, good housekeeping procedures, employee training, process safety analysis, and equipment maintenance. The facility tracks the implementation of these policies in a management database system. This system allows management to update policies and procedures and easily communicate the changes to employees. As part of the RMP, Ameripol Synpol evaluated worst-case scenarios for each chemical. The worst-case scenarios assume that none of the fa cility's mechanical controls or safety systems are operational. In these scenarios an instantaneous rupture of the storage tank wall would occur and release the entire contents in a period of ten minutes. The results of the evaluation indicate that the worst-case release of ammonia could potentially affect an urban area within 2.6 miles of the facility. Public receptors include a school, residences, recreation area, and other commercial and industrial areas. There are no environmental receptors within the worst-case ammonia release area. A worst-case release of butadiene could potentially affect an urban area within 0.4 miles of the facility. Public receptors inside this zone include residences and other commercial and industrial areas. There are no environmental receptors within the worst-case butadiene release area. Ameripol Synpol also evaluated alternative release scenarios for each chemical to simulate more realistic events. The scenario for the alternative release o f ammonia involves the failure of a 6-inch valve gasket that would result in the release of 700 pounds of ammonia in five (5) minutes. Active mitigation systems include a water curtain, alarm systems, trained emergency responders, and a communication link to off-site responders. The results of the evaluation indicate that this alternative-case release of ammonia could potentially affect an urban area within one tenth (0.10) of a mile of the facility. There are no public or environmental receptors within the release area. An alternative release scenario for butadiene involves a reactor seal failure that would allow a release of 600 pounds of butadiene in five (5) minutes and lead to a vapor cloud explosion. Active mitigation includes water curtain, mobile fire protection, alarm systems, trained emergency responders, and a communication link to off-site responders. The results of the alternative evaluation indicate that this release of butadiene could potentially affect an urban ar ea within 150 feet. There are no public or environmental receptors within the release area. ASC's Port Neches Plant is classified as a Program 3 facility because it is covered by the OSHA Process Safety Management (PSM) regulation, and because potential receptors are inside the zone established by its worst-case scenario. This Risk Management Program (RMP) submittal package provides detailed information regarding our plan for complying with EPA's RMP as a Program 3 facility. In order to prevent the above scenarios from occurring, Ameripol Synpol complies with OSHA's PSM regulations for preventing and minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. In addition to PSM, the facility also complies with OSHA's regulation governing Hazardous Waste Operations and Emergency Response (HWOER). Ameripol Synpol also complies with the Environmental Protection Agency's (EPA's) Spill Prevention, Control and Countermeasures (SPCC) Plan r equirements, Oil Pollution Act of 1990 (OPA-90) requirements, and the Emergency Planning and Community Right-to-Know Law (EPCRA). The Port Neches Plant maintains a highly-trained and well-equipped Emergency Response Team. The Emergency Response Team will respond to all emergency action levels, rescue operations, toxic substance releases, and fires. Training is based on the duties and function to be performed by each responder. Employees who participate in the Emergency Response Team are given training in accordance with requirements of 29 CFR 1910.120 Section (q). The Southeast Texas Golden Triangle Area, in which the Ameripol Synpol Corporation plant is centrally located, has available an exceptional emergency assistance organization known as the Sabine-Neches Fire Chiefs' Association. Membership includes all major petrochemical and other industrial organizations in the area, including Ameripol Synpol Corporation, plus all municipal fire fighting and law enforcement organizatio ns in the area. Continuous radio communication monitoring assures quick emergency assistance if and when the need arises. This organization, with others, plans and participates in disaster drills that include local emergency medical services and area hospitals. During the next twelve months Ameripol Synpol will be upgrading its tracking system for tasks related to RMP so that the information related to them is collected in a single place, making planning and resource allocation easier and more effective. A single computerized system will replace a number of systems that were formerly operated independently. |