Perstorp Polyols, Inc. - Executive Summary |
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Executive Summary Perstorp Polyols, Inc. is submitting this Risk Management Plan to fulfill the requirements of Section 112(r) of the Clean Air Act. This plan contains information on the processes involving formaldehyde and acetaldehyde at the Perstorp Polyols' facility, the prevention programs for the processes, the emergency response program for the facility, the necessary release scenario using EPA criteria and guidance documents for modeling, and the facility's five-year accident history. This section is designed to summarize the information contained in the plan and describe the approach to prevention of releases used by Perstorp Polyols in Toledo, Ohio. Accidental release prevention and emergency response policies Perstorp Polyols is committed to operating the facility in a safe and environmentally friendly- manner. We have committed to making continuous progress toward the vision of no accidents, injuries, or harm to the environment. O ne way that Perstorp Polyols demonstrates this commitment is by participating in the Responsible Care initiative. Responsible Care is an initiative developed by the Chemical Manufacturers Association designed to improve performance in the areas of safety, health, and the environment. Perstorp Polyols signed the Guiding Principles of Responsible Care in 1988 and reaffirmed our commitment in 1999 when our President signed the newly revised Guiding Principles. Responsible Care includes management practices that address performance ideals in the areas of process safety, community outreach and emergency response, distribution of products and raw materials, prevention of pollution, employee health and safety, as well as product stewardship. Perstorp Polyols in Toledo has been recommended for certification under the International Standards Organization (ISO) 14001 standard for environmental management systems. This certification means that the Toledo facility has a w orking environmental program that meets the requirements of this international standard as judged by an independent third party verifier. Perstorp Polyols has taken the ISO 14001 standard a step further and has applied the management system to the safety and health of our employees. This step ensures that safety and health issues will be addressed in a systematic manner that strives for continuous improvement. By addressing these matters this way, Perstorp Polyols is incorporating the management practices of Responsible Care with the international ISO 14001 standard in our work every day to reduce the risk of accidents that could result in harm to our employees, the public, and the environment. Perstorp Polyols is also certified under the ISO 9002 standard for Quality Systems. As part of the Risk Management Planning process, Perstorp Polyols has worked closely with the Lucas County Local Emergency Planning Committee. This close working relationship help s educate our emergency responders of the risks that are presented by our facility, the work that is on-going to prevent accidents from occurring and reduce the potential impact of an accident if it occurs, and make them more familiar with our facility. We also benefit from this relationship in that we learn from the experience of our emergency responders in dealing with incidents at other facilities and the preventative actions that can be taken to further reduce the risk of an accident at our facility. Our work with the Lucas County LEPC gave us the opportunity to assist in educating the public about the potential risks of our facility posed by the chemicals covered by the risk management rule and the preparedness of our local emergency responders in the event an accident occurs at our facility. Perstorp Polyols participated in an informational meeting sponsored by the LEPC for public officials within Lucas County and surrounding communities. We also set up a boot h at a local mall with the LEPC and other companies in the county on a Saturday to distribute information about our risk management program, the prevention programs we have in place, and our release scenarios developed using the EPA criteria. Perstorp Polyols annually reports its environmental performance in an environmental report that is issued by the Perstorp Group separately from the annual financial report. The annual environmental report for the Perstorp Group can be found on the Perstorp web-site at www.perstorp.se. Perstorp Polyols' Toledo facility Perstorp Polyols, Inc. is part of Perstorp Polyols AB, a global company active in the application areas of chemistry and materials technology. Perstorp Polyols Inc began operations in Toledo, Ohio in 1977 with the purchase of a Pentaerythritol and Sodium Formate manufacturing facility. Since 1977 the operations have expanded to include manufacturing of Trimethylolpropane and Formaldehyde. In 1997, Perstorp Polyols completed construction and started a new state-of-the-art Formaldehyde plant. This plant was designed using Perstorp Polyols' own technology with stack gas recycling and a catalytic emission control system to reduce emissions by oxidizing volatile organic chemicals to water and carbon dioxide. The Formaldehyde is used both in house in the Pentaerythritol and Trimethylolpropane manufacturing processes and is sold externally for use in the manufacturing of particleboard, clothing and pharmaceuticals. Formaldehyde is one of the chemicals covered by the requirements of the Risk Management Planning rule and is included as part of this submission because it is stored at the facility in excess of 15,000 pounds. Pentaerythritol and Trimethylolpropane are used in the production of resins for paint and coatings, inks and adhesives, lubricants and urethane foam. Sodium Formate is used for paper bleaching, leather tanning, cattle feed and in the production of liquid detergents. Acetaldehyde is a raw material used in the production of Pentaerythritol. Storage of acetaldehyde is included in this submission because acetaldehyde is one of the chemicals covered by the requirements of the Risk Management Planning rule and it is stored at the Toledo facility in excess of 10,000 pounds. Prevention program Perstorp Polyols considers prevention of accidental releases at all stages of the plant operation. This prevention program begins with designing for safety in the processes. All systems are designed according to accepted industry codes. Perstorp Polyols' plants and operating systems are designed and operated with redundant safety systems and instrumentation. The purpose of these systems is to provide back-up safety protection in the event a primary safety system fails. Modern technology is used in the design and construction of processes. All new or modified plants are inspected and reviewed befo re start-up. Tanks used to store chemicals are placed in concrete secondary containment areas to prevent possible leaks or releases from reaching soil, ground or surface water. Most tanks are equipped with high level alarms that alert operators that the tanks are nearly full and some of these alarms are equipped to shutdown the pump that is supplying the tank to prevent overfilling. Another step of the prevention program includes the maintenance of the plants and their safety systems. Preventative maintenance on processes is regularly conducted to protect against equipment failures. While this does not guarantee that equipment will not occasionally break down, it reduces the risk that a problem will occur. Safety systems are inspected and tested regularly to ensure that they will be operational if a problem develops within the process. This includes annual or semiannual inspection and testing of fire suppression systems by outside contractors as well as insp ection and testing of pressure relief devices within the processes. Systems that are designed to shutdown when an upset occurs are often tested during plant downtime to ensure they will function to shut the process down if the upset condition occurs. Perstorp Polyols employees prevent accidents by operating the processes in a safe and efficient manner. Our operators are well trained in operating instructions for the processes. They were involved in the development of many of these operating instructions, either by reviewing the instructions when they were being written or by writing the instructions themselves. Written unloading and operating instructions are regularly reviewed and kept up to date. Perstorp Polyols believes that safe design, good maintenance practices, and well-trained operators are very important parts of the prevention program. However, we have found that a key part of managing our processes is taking a critical and independent look at our operation on a regular basis. These reviews are designed and used to ensure that we do what our procedures say that we are doing. Therefore, Perstorp Polyols conducts audits and reviews on safety and environmental systems as well as the operational phases of our facility. We use internal reviews of procedures and operations to verify they reflect the appropriate level of safety, quality and environmental protection. Independent third-party verifiers regularly review our quality and environmental management systems to ensure that Perstorp Polyols continuously improves the operation of the facility. In addition to the work under the ISO standards described earlier and the Responsible Care initiative, Perstorp Polyols incorporates the requirements of government requirements such as the OSHA Process Safety Management Standard and the EPA Risk Management Plan in the overall management system for safety, health and the environment. This ensures that protecti on of the environment and employee safety is a part of every day operations at Perstorp Polyols. Emergency Response Program Despite the prevention program described earlier, Perstorp Polyols must prepare and plan for emergencies that may occur. There are many government regulations that require emergency plans and in 1996, OSHA, EPA, Coast Guard, and Department of Transportation worked together to develop a uniform plan for emergencies. That plan, called the Integrated Contingency Plan, is used at Perstorp Polyols to provide a single source of information and procedures in the event of an emergency. Copies of the plan have been provided to the Toledo Fire and Police Departments, several local hospitals, and the Ohio EPA so they are aware of the emergency plan at Perstorp Polyols. Training is provided to our employees on the plan at least once a year. Evacuation drills for employees are conducted annually as well. The facility is equipped with an emergency alarm that sounds throughout the facility to alert employees. This alarm is tested regularly to ensure that it is operational and can be heard throughout the facility. Occasionally drills are performed on-site in conjunction with the Toledo Fire Department Hazardous Materials Unit. Perstorp Polyols also takes an active role in the Lucas County Local Emergency Planning Committee (LEPC). Our participation in this group with emergency responders includes assisting in planning large-scale drills and public education of risks and emergency preparedness. Five-year accident history Perstorp Polyols is including data elements on two formaldehyde releases in the five-year accident history portion of this report. The first release reported in this submission is a pump failure on June 13, 1997. The release was contained on-site primarily to concrete and stone areas. There was no off-site impact as a result of the release. The release was reported to Ohio EPA, the National Response Center, the City of Toledo Division of Environmental Services, and the Lucas County LEPC. A containment area has been installed around the pump to prevent any future releases from spreading to the stone areas. The second release reported in this submission occurred in June and July of 1994. A heat exchanger using water from the Ottawa River for non-contact cooling leaked and formaldehyde was released into the Ottawa River. The leak was discovered on July 7, 1994. The river was depleted of dissolved oxygen as a result of the release, but recovered after the leak was repaired. The City of Toledo Division of Environmental Services estimated the leak began on or about June 13, 1994. No off-site injuries occurred and no evacuations were required. A cooling tower was installed to provide non-contact cooling water and the use of river water was discontinued by March 1995. Perstorp Polyols has not had an accidental release of acetaldehyde within the past five years. Worst case release scenarios and alternative release scenarios Perstorp Polyols is submitting two situations that meet the EPA criteria for worst-case release scenarios. One situation covers the storage of acetaldehyde and the second situation covers the storage of formaldehyde. Perstorp Polyols is also submitting two situations that are required under EPA criteria for alternative release scenarios; one for acetaldehyde and one for formaldehyde. All four situations have off-site impacts in that modeling indicates the impact will leave the facility property. Perstorp Polyols has used the EPA Off-site Consequences Analysis Guidance for modeling these situations. Based on this guidance, none of the situations will have an impact on residential areas. Acetaldehyde is a clear, colorless liquid solution. It has a pungent, fruity odor that can irritate the eyes, nose, and throat at low levels. If released int o the air, acetaldehyde may form a vapor cloud that presents a fire or explosion hazard if not properly contained. Perstorp Polyols stores acetaldehyde in pressurized tanks equipped with a nitrogen blanket to reduce the flammability of the vapor if released. According to the EPA criteria for worst-case scenarios, Perstorp Polyols assumed that two interconnected storage tanks of acetaldehyde failed completely. The resulting release would spill into a concrete secondary containment area. The EPA criteria require us to assume that the tanks were 100% full and that entire amount would instantaneously vaporize and explode. The EPA criteria for alternative release scenarios require us to assume a more likely release situation. The more likely situation chosen for acetaldehyde is a leak from a two-inch diameter unloading hose during transfer of acetaldehyde. This situation was chosen because it had the furthest off-site impact of the more likely release situations analyzed. The leak point is railroad unloading station near Dura Avenue. The release is assumed to occur for 10 minutes. A leak is unlikely to occur for longer than 10 minutes since an operator attends the unloading process at all times. If a leak develops in this area, the operator would respond immediately to shutdown the unloading process and this action would stop the leak. Formaldehyde is a colorless liquid solution containing about 52% formaldehyde. It has a pungent, irritating odor that can irritate the eyes, nose, and throat at low levels. Formaldehyde is a material that auto-polymerizes; that means on standing in normal temperature formaldehyde solution forms a white solid called paraformaldehyde. Under the EPA criteria for worst-case scenarios, Perstorp Polyols must assume one of the largest storage tanks of formaldehyde completely fails and the contents of the tank spill into a concrete secondary containment area. The formaldehyde is assumed to evaporate into a vapor cloud that may travel in any direction from the facility. The secondary containment area will limit the surface area of formaldehyde available for evaporation to 4,540 square feet. It is assumed that no actions by the plant operators is taken as the EPA criteria require us to assume that systems or personnel that could act to contain or stop the release fail to operate as designed or according to procedures. The EPA criteria for alternative releases allow evaluation of more likely release situations. Perstorp Polyols has evaluated potential release situations and past accidents discussed in the five-year accident history section to determine the situation with the furthest off-site impact. The alternative situation submitted for formaldehyde is a pump failure that causes a release in the concrete secondary containment area. The modeling assumes the release occurs for 10 minutes and the total surface area covered by the release is 2,270 square feet. Within 10 minutes, a plant operator will be able to shutdown the failing pump and isolate the storage tank or process flow to prevent additional leakage. The operator would also take action to dilute the formaldehyde with water and reduce the amount of formaldehyde evaporation that would take place. The operator would also begin to pump the material from the containment area into process tanks for reprocessing and reuse. Planned changes to improve safety Perstorp Polyols has a commitment to continuous improvement in the areas of safety, health and the environment. This commitment is demonstrated in the semi-annual audits of our environmental management system by independent verifiers, the weekly safety and environmental training program for our employees, as well as our on going suggestion program for our employees. The suggestion program gives our employees the opportunity to submit recommendations for changes with the plants or proc edures to improve safety, environmental protection, operational efficiency, and many other areas. The next audit of our environmental management system is scheduled for October 1999. Internal audits of our operations are on going throughout the year. |