CASE STUDY 1985 Shutdown and Restoration of Delaware City PVC Plant
WHAT LED TO EPA's SHUTDOWN OF FPC DELAWARE OPERATIONS IN 1985?
The major causes of the EPA's shutdown of the Formosa Plastics (FPC) Delaware City PVC plant were a combination of "poor initial design and poor maintenance." These problems were compounded by the existing management group's inability to insure that operations were done correctly. In addition, inadequate communications with the state's EPA created a misunderstanding of reporting requirements.
The EPA ruled that the plant presented a hazard to the immediate community, revoked operating permits on October 25, 1985, and ordered the facility's three plants to be shut down by midnight October 31,1985.
WHAT HAPPENED AFTER THE SHUTDOWN?
Discussions with the State of Delaware began to determine whether the plant should be closed down permanently or whether it could be operated in the future.
Negotiations began with state officials to reopen the plant. A list of "must do" items was generated directed at equipment integrity. This list included items such as piping and vessel thickness checks and instrumentation calibration and interlock tests. In addition, the EPA insisted on putting into place new management systems to insure continued compliance with the regulations.
HOW DID THE PLANT RETURN TO OPERATIONS?
A consent order was entered into between Formosa and the State of Delaware listing items that both parties agreed were reasonable and attainable as well as a timetable for completion. Formosa's ability to continue operation depended on implementation of management controls to insure good, smooth operation on a continuous basis.
Under the direction of new plant manager Larry Peyton (brought in from the company's Point Comfort plant in Texas), work began under the watchful eye of an EPA appointed consultant. As the list of "must-do" items were completed, facility start ups came in stages.One plant restarted on November 26, 1985, a second plant reopened on December 3, and a third on December 27, 1985.
These management systems put in place were in a large part standard to FPC management, however they had not been adequately put into force at the company's Delaware City plant. They included such things as implementing a comprehensive preventive maintenance system, better managing change and abnormal analysis systems, instituting more rigid operator qualifications and training, and encouraging all personnel to participate in an improvement suggestion program.
Improved communications with the State officials also helped build confidence and trust.
As new management measures became part of the daily routine and design problems were corrected, the operation of the plant as well as the environmental performance improved. A year later, no emergency releases of VCM were recorded, a new standard for the industry, and the facility began showing a profit for the first time since it was constructed.
MAJOR ACCOMPLISHMENTS
Became the only plant in the USA producing PVC or VCM reporting any VCM level of 50 ppm in the work environment, exceeding EPA requirements.
Stopped the land disposal of any production related waste material to meet our own requirements of waste minimization. Again this was not an EPA requirement.
Lowered the TWA (time weighted average over 8 hours) VCM exposure data for all our plant employees to below 1 ppm. This was almost unheard of in a cold weather plant that is enclosed.
Reduced residual VCM in the product to below 80%, less than that required by the EPA.
Recognized in national publication "Chemical Processing" for pollution control measures and environmental performance. See article
Recognized by major industry neighbors for exemplary performance. Larry Peyton, plant manager, was elected president of the Delaware Chemical Industry Council. The council is composed of 18 chemical companies including DuPont, Hercules, and ICI, which have their head offices in Wilmington, Delaware, the chemical capital of the USA.
Praised in May, 1987, by the Governor of Delaware at a joint meeting of the Delaware legislature and the Chemical Industry Council of Delaware referring to the Formosa plant in Delaware City as a good example of environmental performance.
Transforming an Old Plant into a Profitable and Environmentally Sound Venture
Chemical Processing (June 1988) reports on technical and management strides made at Formosa Plastics Delaware plant under direction of Larry Peyton. Click link below.