BFGoodrich Performance Materials Louisville Plant - Executive Summary |
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BFGoodrich Louisville Plant Risk Management Plan Executive Summary The BFGoodrich Performance Materials plant in Louisville, Kentucky is a specialty chemical manufacturing facility located in the Rubbertown Area. The plant began operation in 1942 to produce rubber products for World War II, along with other plants in the surrounding vicinity. Thus, the name Rubbertown was established. Today, BFGoodrich Louisville produces over 100 different products that are consumed both in the United States and abroad. Our Latex products are used in paper coatings, automotive interiors, and nonwoven cloth. We are the world's largest producer of CPVC Resins and Compounds which are used in plumbing, fire sprinkler, and industrial piping systems. We have 164 employees with annual payroll of $11.6 million, paying approximately $768,000 in local and state payroll taxes annually. Each year we purchase approximately $3.8 million in goods and services, mainly from local suppliers and approximately $2 .2 million in utilities. We pay approximately $220,000 in real estate/property tax and $180,000 in sales taxes. Our plant uses certain chemicals as raw materials which are regulated by the EPA Risk Management Program (RMP) Rule. These are vinyl chloride and vinylidene chloride, which are flammables under the RMP; and chlorine and vinyl acetate, which are toxics under the RMP. The types of programs recently required by the RMP to prevent serious accidents and to plan contingencies have long been in place at the BFGoodrich Louisville plant. We understand the relationship between good safety and good business, which is reflected by our exemplary and frequently awarded safety performance. Nevertheless, we welcome the EPA's RMP initiative and see it as another opportunity to expand dialog with our community. Accidental Release Prevention Program and Emergency Response Programs at The Stationary Source It is the policy of the BFGoodrich Louisville plant to conduct our ope rations and business activities in a manner which protects our communities, our environment, and our employees. Our daily activities comply with applicable laws and regulations, the Chemical Manufacturers Association Responsible Care Program, and the BFGoodrich Performance Materials Health, Safety and Environmental Policies. The General Accident Prevention Program and Chemical Specific Prevention Steps The BFGoodrich Louisville plant has in place a thorough, ongoing program of process safety management (PSM). The program includes procedural and engineered safeguards to prevent catastrophic releases and explosions. Some highlights of our program include: 1) Employee Participation - Employees from various areas of expertise are involved in numerous activities to continuously improve plant safety. Employee participation is key in the following areas: safety committees, audits, pre-startup safety reviews, process hazard analysis, training, procedure development and monthly sa fety meetings. 2) Process Hazard Analysis - Various process hazard analysis techniques are performed to identify and analyze the potential hazards associated with the chemicals and processes we use. Corrective action plans are developed and implemented as part of the analyses. The PHA's are updated a minimum of every five years. 3) Operating Procedures - Operating procedures have been developed for all processes to insure safe operation. Those involved with the manufacturing process are included in the development, training and periodic review of these procedures. Our processes are ISO - 9002 certified and subject to external auditing every six months. 4) Employee Training - Training programs have been developed and implemented to ensure all affected employees understand the hazards of the chemicals used and the required safe handling procedures. The Plant has established an operator training program to train, test, and qualify employees involved in operating the chemical processes. The program is completed by new employees. All employees are re-certified a minimum of every three years. 5) Mechanical Integrity - This program was established to insure the integrity of process equipment. Elements of this program include the following: 7 Identification and categorization of equipment and instrumentation 7 Inspections and tests 7 Establishment of prescribed inspection frequencies 7 Development and application of maintenance procedures 7 Training of maintenance personnel 7 Documentation of tests and inspection results 6) Pre-Startup Safety Reviews - Safety reviews of new processes, major projects, and new chemicals are conducted to ensure safe transition into the operating mode. 7) Hot Work Permit - This system manages welding, cutting, brazing and other ignition sources throughout the plant to prevent fires and explosions. 8) Management of Change - This procedure is in place to properly manage the changes involving processes, chemicals, technology , equipment or facilities. 9) Contractors - Contract companies are evaluated to insure they have the appropriate job skills, knowledge, training and certification to perform work safely. All contract personnel must complete a BFGoodrich training class prior to entering the facility. Training must be repeated annually. 10) Incident Investigation - Any incidents or near misses involving the release of hazardous material are investigated by a team of skilled plant personnel. These investigations identify corrective actions, evaluate our management systems and are documented and communicated through a narrative report. These reports are circulated to all BFGoodrich Performance Material sites. The corrective actions are tracked for timely completion. 11) Compliance Audits - Audits of our process safety management systems are conducted of every three years. These audits review all documentation, verify process safety information and inspect the physical facilities. Five Year Acc ident History The RMP rule requires each company to include a description of all accidental releases within the last five years which resulted in deaths, injuries, significant property damage on-site; known off-site deaths, injuries, evacuations, sheltering in place, property damage or environmental damage. The BFGoodrich Louisville plant has had no events meeting this criteria. Emergency Response Program The BFGoodrich Louisville plant has an emergency response plan that is coordinated with the Jefferson County Local Emergency Planning Committee (LEPC), Lake Dreamland Fire Department, Rubbertown Mutual Aid Association, and other local response agencies. Plant personnel are trained annually on the plan and new employees are trained prior to working in a process area. Our emergency response team maintains 24-Hour Hazardous Material Technician certification to mitigate an accidental release. In addition, the plant maintains a dispersion modeling system which does "real time" va por cloud dispersions and can give indications of affected neighborhoods in the community. Worst Case and Alternative Case Release Scenarios The RMP rule provides a detailed prescription for a worst case scenario (WCS). Under the prescription, we have identified two WCS: one for a toxic material and one for a flammable material. In both cases, the RMP rule requires that the largest storage vessel experiences a catastrophic failure and releases all inventory within ten minutes. This scenario would occur under very stable weather conditions and at a low wind speed. Based on previous history, in addition to the several layers of protection in place; we find these scenarios to be highly unlikely. The RMP rule also provides a prescription for what should be considered for an alternate release scenario (ARS); however the rule does allow more flexibility when determining these scenarios. Under the prescription, we have identified three ARS: one for each toxic material (2) and one for flammables as a class. The scenarios we have identified are more credible than those described in the worst case, but are still very unlikely given of protection redundancy and level of training. The following is a description of our scenarios: Worst Case Toxic The first scenario involves chlorine, which is considered a toxic gas under the RMP rule. This scenario involves the loss of the entire inventory of a 180,000 pound railcar over a ten minute period. The EPA's tabulated dispersion predictions were used to determine the toxic endpoint of this material, which obviously could have a significant off-site impact. We are unaware of any incident in international history where a railcar vessel has spontaneously ruptured. Currently, the plant has administrative controls such as procedures and training, which address the proper handling of railcars. Worst Case Flammable Our second scenario involves releasing the inventory of a 295,000 pound vessel containing vinylidene chlor ide (VDC). Vinylidene chloride is a flammable liquid under the RMP rule. The RMP rule assumes the vessel contents would be released, accumulated in the vicinity of the vessel, ignited, and result in a vapor cloud explosion (VCE). We have applied the VCE formula contained in the EPA's guidance and predicted endpoint distances to a one psi overpressure. There is prevention and mitigation equipment in place to minimize this possibility. The VDC tank is currently in our PSM program and undergoes integrity testing and inspections on a routine basis. The area is constantly monitored with explosive gas detectors, which are tied into a water suppression system surrounding this vessel. Alternate Release Scenario (ARS) - Chlorine (Toxic Gas) The RMP rule requires an alternate release scenario (ARS) be conducted for each covered toxic material. The alternate chlorine scenario we have identified is highly unlikely but is more credible than the worst case scenario. A committee consisting of employees skilled in the operation of the affected process selected the scenario. The committee evaluated past history and process hazard analysis to identify the most credible scenario. The committee evaluated multiple potential release scenarios. Upon further analysis, the group decided that the release from an unloading hose would be the alternative release scenario for chlorine. The following is the scenario description: A railcar containing 180,000 pounds of chlorine is stored as a pressurized liquefied gas at an ambient temperature of 25C. The storage pressure is approximately 135 psig. A 12 ft. long, 1 inch diameter unloading hose connected to the railcar ruptures. The excess flow valve fails to close completely. The release is detected and stopped within 30 minutes. The EPA's tabulated dispersion predictions for alternate release scenarios was used to determine the toxic endpoint. The plant has established preventive maintenance activities for the unloading hoses including a routine change out program. In addition, a sophisticated chlorine monitoring system is in place throughout the process area. Alternate Release Scenario - Vinyl Acetate (Toxic Liquid) A committee consisting of employees skilled in the operation of the affected process selected this scenario. The committee evaluated past history and process hazard analysis to identify the most credible scenario. The committee evaluated multiple potential release scenarios. The committee agreed that the most credible scenario meeting the requirements of the ARS would be the failure of the unloading hose. The following scenario was developed: Vinyl Acetate is delivered by railcar and transferred to the storage tank in the 300 Series Tank Farm. During the unloading operation, the fittings are not properly installed. When the car is pressured to 18 psi. to begin unloading, the connection fails. The leak would be uncontained and would not be stopped for a minimum of thirty minutes. T he release rate would be 2940 lbs/min. The EPA's tabulated dispersion predictions for alternate release scenarios were used to determine the toxic endpoint. The plant has established administrative controls such as training and operating procedures, to prevent this type of incident. Alternate Release Scenario - Vinylidene Chloride (Flammable Liquid) The process of unloading this product is very similar to that of vinyl acetate. Actually, the same unloading station is used for both materials and the procedures are also very similar. Again, a committee consisting of employees skilled in the operation of the affected process selected this scenario. The committee evaluated past history and process hazard analysis to identify the most credible scenario. The decision process involved pipe leaks, over pressure of a reactor, storage tank leak, and the failure of the unloading hose. The committee agreed the most credible scenario meeting the requirements of the ARS would be the failure of the unloading hose. The following scenario was developed: Vinylidene chloride is delivered by railcar and transferred to the storage tank in the 300 Series Tank Farm. During the unloading operation, the fittings are not properly installed. When the car is pressured to 18 psi to begin unloading the connection fails. The leak would be uncontained and would not be stopped for a minimum of thirty minutes. The release rate would be 4630 lbs/min. At this time, the release reaches an ignition source and becomes involved in a VCE. We have applied the VCE formula contained in the EPA's guidance for ARS and predicted endpoint distances to a 1 psi overpressure. The plant has established administrative controls such as training and operating procedures to prevent this type incident. Planned Changes to Improve Safety At this time, we have no immediate changes planned for the near future. However, we will constantly investigate means and challenge ourselves to improve safety througho ut the plant. Our safety program is integrated into all facets of plant operation and involves the identification and implementation of numerous means to improve safety performance. These efforts will continue to be our focus for both process and personal safety. |