BFGoodrich Textile Chemicals, Inc. - Executive Summary |
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The Stationary Source and Regulated Substances Handled The BFGoodrich Charlotte Plant is a specialty chemical manufacturing facility located eight miles west of downtown Charlotte and three miles east of Belmont in Mecklenburg County, North Carolina. It is situated on a 74-acre property surrounded by light industry, commercial establishments, and residences. We manufacture 10 different types of chemical products, 95 percent of which are consumed in the U.S. and the rest are sold on the international market. Our products include several chemicals used to solve problem properties of fabrics, so that fabrics are stronger, softer, shrink-free, and release soil easily; have durable press; have no dye migration or bleeding; and can be water repellant and flame retardant. Other related products strengthen adhesives and paper products. We also make sulfated oils, which are used extensively in making textile, leather, pulp and paper, paint and coatings, and personal care products. They a re useful as bleaching assistants, lubricants, defoamers, dyeing assistants, emulsifiers, dispersants, rheology modifiers, and emollients. Much of the sulfated oil chemistry is based on naturally occurring oils which make them easily biodegradable. At the Charlotte Plant, we have 74 employees with an annual payroll of $4.1 million, paying about $100,000 in city and county taxes annually. Each year, we buy about $25 million in goods and services, and pay about $2 million for utilities and $1.8 million for freight services. Our plant uses one chemical that brings us under the EPA Risk Management Program (RMP) Rule. This is a 50% formaldehyde solution, which poses a toxic vapor release hazard under the RMP Rule. We have one 20,000 gallon storage tank of this solution on-site, which is the minimum practical quantity for our production processes. The types of programs recently required by the RMP to prevent serious accidents and to plan emergency contingencies have long been in place at the BFGoodrich plant. We have long understood the relationship between good safety and good business, as reflected by our exemplary safety performance. In 1997, we received the North Carolina Department of Labor Safety Award, having an injury record 50% better than the state-wide average for our industrial classification. Nevertheless, we welcome the EPA's RMP initiative and see it as an opportunity to continue and expand dialog with our community. The Accidental Release Prevention Program and Emergency Response Policies at the Stationary Source It is the policy of the BFGoodrich Charlotte Plant to meet and often exceed all requirements established by applicable safety, health and environmental regulations promulgated by Federal and state agencies. Our safety policies and practices have historically preceded the regulation of such practices under, for example, the OSHA Process Safety Management Standard and the EPA Risk Management Program Rule. Our policy is to maintain at a practical minimum the potential for harm to on-site employees and contractors, the public, and the environment, and to have in place contingency actions, coordinated with local responding agencies, for the unlikely event of a serious accidental chemical release. A related program in which we are participating is a company-wide Year 2000 ("Y2K") effort to ensure that Y2K issues associated with our computer-based systems and those of our suppliers will not impact our current safety achievement. Another safety-related program in which we participate is Responsible Care. under the Chemical Manufacturers Association, and we are certified under the ISO-9000 international quality standard. The general accidental release prevention program and chemical-specific prevention steps The BFGoodrich plant has in place a thorough, ongoing program of process safety management (PSM). This program calls for implementation and maintenance of procedural and engineered safeguards at the plant to mini mize the likelihood of a significant release of a hazardous chemical, and to eliminate or reduce the effects of any release that might occur. We have invested and continue to invest substantial effort and capital in maintaining our strong safety performance. Some examples of our investments in the past year include installing dock locks and safety gates at a cost of $105,000, updating our piping and instrumentation diagrams at a cost of $80,000, and purchasing confined space equipment at a cost of $20,000. Several other investments are also planned, including: - Chemical loading racks, at an anticipated cost of $220,000 - Formaldehyde absorber, at an anticipated cost of $140,000 - Reactor sprinkler system upgrade, at an anticipated cost of $28,000. We also have a plan for the diking of all storage tanks over the next five years, at an anticipated cost of $3 million. We are involved in day-to-day safety-focused activities under our program that includes elements such as: (1) Proce ss Hazard Analyses - we routinely perform and maintain up-to-date, systematic and thorough studies of our operations to identify what could go wrong, identify means of eliminating or reducing design or procedural weaknesses, and implementing improvements. (2) Process Design - our processes and equipment are designed for safety in accordance with applicable industry standards and best engineering practices. Designs include, as appropriate, automatic emergency shutdown systems, pressure relief devices, and ventilation systems. (3) Training - our operations and maintenance personnel are trained thoroughly on their job tasks, on safe work practices as they apply to their jobs, and emergency contingency actions, before they may operate or maintain equipment. They also receive refresher training periodically. Our procedures for operating and maintaining processes, general safe work practices, and emergency response, are fully documented and maintained up to date in light of any changes at the plant. (4) Maintenance - Each item of equipment at our plant that is involved in maintaining safety or in responding to an abnormal situation is inspected, tested and/or maintained on a frequency that reflects its service and condition. (5) Management of Change - no change to equipment or procedural practices can take place at the plant without a thorough review of the implications of that change to safety. No change must adversely impact the safety built into the design and operations of our processes. Our PSM program is tuned to reflect the specific hazards of the chemicals we use. For example, our operating, maintenance, safe work, and emergency procedures address personal protective equipment appropriate to the chemicals being handled. Also, equipment is selected based on its intended service and chemical exposures. The Five-Year Accident History We have had no events at the BFGoodrich Charlotte plant that would qualify for inclusion in the RMP 5-year accident histo ry. The Emergency Response Program We have in place a written emergency response plan that we coordinate with the West Mecklenburg Volunteer Fire Department (VFD), which is backed up by the Charlotte Fire Department. New personnel are trained on the plan, we conduct refresher training annually, and we train on any revisions to the plan. The plan is in compliance with the RMP requirements, as well as other applicable EPA and OSHA requirements. The VFD has had on-site rescue training; we also invite local HAZMAT crews to the site. The Worst-Case Release Scenario and the Alternative Release Scenario The RMP Rule provides a detailed prescription for what should be considered a worst case scenario (WCS). Under that prescription we have identified and analyzed our WCS, which is a sudden, catastrophic failure of a full formaldehyde storage tank, resulting in spillage of the formaldehyde solution into the containment dike surrounding the tank. Based on use of the EPA Offsite Consequenc e Analysis Guidance, this scenario is calculated to have offsite impacts under worst-case meteorological conditions. A more likely scenario, called an alternative release scenario (ARS), was also analyzed. As required by the RMP Rule, we chose a hypothetical ARS that is severe enough to have an effect beyond our fenceline. This ARS is nevertheless a highly unlikely scenario of the type our process safety management program protects against. In our ARS, the operator is pumping formaldehyde solution from a tank truck to the storage tank. The unloading hose or piping is hypothesized to suddenly and totally fail. The formaldehyde solution begins to spill onto the paved surface and evaporate. Even though personnel are in immediate attendance during the entire unloading operation and can very rapidly stop the transfer, the ARS allows the spill to continue for a full minute before being interrupted. The release is calculated (using EPA Guidance) to have impact beyond our fenceline, re aching a commercial/industrial neighbor if the wind is blowing in one particular direction, but not reaching any residential areas. The safeguards in place against this scenario, in addition to immediate operator attendance, are (1) the transfer hose and connections are required by procedure to be inspected before each transfer; (2) any leak or break in the transfer connection can be rapidly isolated by way of a manual valve on the truck side of the flexible connection; (3) if the manual valve cannot be closed or accessed, a hydraulic valve can be actuated at the rear of the truck that will automatically shut off the transfer pump; (4) a chemical sewer drain is located at the unloading station, so any spilled material will go into the chemical sewer where it will be cooled and diluted to stop evolution of formaldehyde vapors, then be captured and treated on-site; and (5) the plant spill response team is trained to handle such a scenario, and would use fire water if necessary to furthe r dilute the spilled material and knock down vapors. We expect scenarios such as this ARS to continue to be hypothetical and unlikely due to our ongoing program of process safety. |