Solutia Inc., Indian Orchard Plant - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Solutia's Indian Orchard Plant, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides an overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency response program * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment STATIONARY SOURCE AND REGULATED SUBSTANCES The Indian Orchard Plant was established by the Fiberloid Corporation in 1904 and purchased by Monsanto Company in 1938. The company acquired an adjoining facility, the Shawinigan Resins facility, in 1963 - creating the current site. The plant took the Indian Orchard name in 1982. Solutia Inc. was formed in 1997 following a spin-off from Monsanto. Today the site includes manufacturing units producing high value specialty products which include Saflex interlayer, Gelva adhesives, Butvar resin, Resimene coatings, as well as a Technical Center complete with research laboratories and pilot plant facilities. The plant occupies 250 acres and has about 750 employees (including contractors). In our processes, we use the following chemica ls that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Vinyl Acetate Vinyl acetate is shipped in rail cars as a liquid to the Indian Orchard plant by suppliers. An average of 4 rail cars of vinyl acetate are stored at the plant. Solutia has strict unloading and handling procedures for the material. The largest above ground storage tank holds 1,200,000 pounds. Solutias Indian Orchard Plant uses vinyl acetate to make adhesives and in the manufacturing of polyvinyl butyral, a plastic interlayer used in laminated safety glass for automotive and architectural applications. Formaldehyde Formaldehyde in a water solution (formalin) is shipped in tank trucks to the Indian Orchard Plant. Solutia has strict unloading and handling procedures for the material. The largest above-ground storage tank of this material holds 700,000 pounds. Solutias Indian Orchard Plant uses formaldehyde to make Resi mene metal coatings used in automotive paints and other industrial applications. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario and alternative release scenarios for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemicals The scenario selected at the Indian Orchard Plant involves vinyl acetate. A stationary rail car storage tank of vinyl acetate holds a maximum of 210,000 pounds and would assume the entire contents of the tank is released to a flat, non-absorbing surface. No administrative controls or mitigation controls are assumed for this worst-case scenario. The resultant plume would have offsite consequences into the greater Springfield area. Alternative Release Scenarios - Regulated Toxic Chemicals Vinyl Acetate: The alternative release scenarios developed for vinyl acetate involve a two inch hole in the bottom of a rail car. The leak from the rail car two inch hole would yield an off-site consequence and would be mitigated by the sites Emergency Response Team. Another alternative release scenario considered was a leak from a pump on the large above ground storage tank. Emergency Response Team would be required to stop the pump and close the pump upstream valve stopping the leak. The pump leak would yield a slight off-site consequence. Formaldehyde: The alternative release scenario developed for the formaldehyde in water solution involves a leak from the pump on the 700,000 pounds above-ground storage tank. Response wou ld require that the manufacturing department operator stops the pump and the sites emergency Response Team close off the pump upstream valve stopping the leak. The leak would yield a slight off-site consequence. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors As part of our prevent ion efforts, we have implemented the following chemical-specific prevention steps: DESIGNING for Safety 7 Vessels designed and constructed under American Society of Mechanical Engineers (ASME) code standards. 7 All systems and components designed to meet or exceed government standards. 7 Fail safe and pressure relief valves. 7 Secondary containment for storage tanks. 7 Formalin storage tanks surrounded by covered containment dikes. 7 Rail car and tank truck unloading performed over containment areas. 7 Flow controller/regulator systems. 7 Automatic shutdown devices and alarms for critical control systems. 7 Operator interface systems. 7 Multiple layers of protection for all safety critical systems. MAINTAINING our Plant 7 Routine inspection and testing of entire systems by highly skilled and trained maintenance personnel. 7 Annual inspection of critical equipment, including automatic shutdown devices. 7 Preventive maintenance for all critical vessels, including spot x-ray of pi pe joints and hydrostatic testing of assemblies. 7 Computerized scheduling, tracking, and notification system - Safety Inspection and Maintenance System - to keep maintenance on schedule. OPERATING Safely 7 All site operations continuously monitored and controlled by computer systems that automatically shutdown systems to preserve safety. 7 Continually manned control room to oversee the computer system as part of a multiple-level, manual backup system. 7 Operators trained on current operating procedures. 7 Random drug testing for all personnel in safety critical jobs. 7 Written operating procedures and standards based on OSHA, EPA and company wide requirements. 7 Procedures certified annually under OSHA standards and higher company requirements. 7 Formal hazard analysis studies conducted on critical operations by trained and certified teams. 7 Manage inventories to minimize risk and to maintain minimum quantities consistent with manufacturing needs AUDITING our Operations 7 Awarded 1997 Star Site in the OSHA Voluntary Protection Program(VPP). 7 Routine external audits by OSHA, EPA, U.S. Department of Transportation and Massachusetts DEP. 7 Corporate audits conducted every three years by Corporate Safety, Health and Occupational Medicine groups, most recent in 1998. 7 Corporate Environmental audit conducted every three years, most recently late 1997. 7 Internal audits conducted every three years on our OSHA Process Safety Management(PSM) systems. 7 Process Hazard Analysis conducted and updated every 5 years per the OSHA PSM standard. 7 Routine operations and maintenance audits of equipment and systems. 7 Complete investigations of all accidents and incidents. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. There has been no releases of chemicals involving materials covered under EPA's RMP rule during the past five years: No significant on site property damage has occurred during the past five years. EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. Training and Preparation 7 24-hour on-site Emergency Response Team (ERT) training includes advanced interior and exterior structu ral fire fighting, hazardous material emergency response, confined space and technical rescue. 7 Specialized teams and technical specialists dedicated to off-site response for hazardous material transportation emergencies. 7 All personnel in departments handling RMP chemicals trained annually in emergency shutdown procedures. 7 Solutia Fire Department trained routinely in cooperation with municipal fire, police and ambulance crews. 7 Active participation in the City of Springfield Local Emergency Planning Committee. If a Release Occurs 7 Department operators proceed to shutdown and isolate the entire system. 7 ERT alerted and dispatched. 7 Operations alerted and dispatched. 7 Preplanned release drill scenarios put into action. 7 ERT equipment throughout plant activated to minimize release impact. 7 Environmental personnel alerted and dispatched 7 Springfield Fire and Police Departments and LEPC contacted to activate city emergency plan if needed. Community Emergency Response 7 Onc e notified by Solutia, Springfield Emergency management System notifies local public safety officials. 7 Local law enforcement and fire departments will alert community via public address speakers, radio, television and door-to-door and will advise whether to shelter in place or evacuate. 7 Affected persons follow emergency procedures for sheltering in place, considered a proven method for protecting individuals and families in the event of an accidental release. PLANNED CHANGES TO IMPROVE SAFETY Solutias Indian Orchard Plant is committed to the principals of continuous improvement in all areas of safety. This is key to our participation in OSHAs Voluntary Protection Program. Our plant is constantly upgrading its operations and safety systems to improve the level of protection. |