Intertape Polymer Group, Columbia - Executive Summary |
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TABLE OF CONTENTS 1.0 CERTIFICATION STATEMENT 2.0 EXECUTIVE SUMMARY 3.0 OFFSITE CONSEQUENCE ANALYSIS 3.1 Worst-Case Release Scenario 4.0 FIVE-YEAR ACCIDENT HISTORY 5.0 PREVENTION PROGRAM 6.0 RISK MANAGEMENT PLAN FIGURES Figure 1 Topographical Map Figure 2 Site Map Figure 3 Offsite Consequence Analysis - Worst-Case Release Scenario 1.0 CERTIFICATION Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worse case accidental release scenario for the following process is less than the distance to the nearest public receptor. Intertape Polymer Group (IPG), Incorporated operates an adhesive tape manufacturing facility located in Richland County, Columbia, South Carolina as shown in Figure 1. IPG must comply with the Chemical Accident Prevention rule issued by the United States Environmental Protection Agency (EPA) under the Clean Air Act. A Risk Management Plan (RMP) is required for the IPG facility. IPG has the potential to store approximately 3 0,000 pounds of toluene diisocyanate (TDI) at their facility at a given time. The TDI is stored in 55-gallon drums weighing approximately 450 pounds each. All of the drums are stored in a designated warehouse as shown in Figure 2. Within the past five years, the process has had no accidental release that caused offsite impacts provided in the risk management program rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion, or a release of TDI from the process, entry within distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged within the emergency contact indicated in the RMP. The undersigned certifies that, to the best of my knowledge, information and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete. Mr. Jay Alconta Sign ature Print Name Director of Operations Title Date 2.0 EXECUTIVE SUMMARY Intertape Polymer Group (IPG), Incorporated operates an adhesive tape manufacturing facility located in Richland County, Columbia, South Carolina as shown in Figure 1. IPG must comply with the Chemical Accident Prevention rule issued by the United States Environmental Protection Agency (EPA) under the Clean Air Act. A Risk Management Plan (RMP) is required for the IPG facility. IPG has the potential to store approximately 30,000 pounds of toluene diisocyanate (TDI) at their facility at a given time. The TDI is stored in 55-gallon drums weighing approximately 450 pounds each. All of the drums are stored in a designated warehouse as shown in Figure 2. IPG uses all reasonable safety evaluations and training requirements to ensure the proper offloading, storage, and transport of TDI. In case of an emergency, it is IPG's policy to immediately notify the City of Columbia Fire Department by calling 911. It is also IPG's policy to notify the Local Emergency Planning Committee (LEPC) Richland County Emergency Preparedness Office, the State Emergency Response Commission (SERC) DHEC, and the National Response Center (NRC). IPG has modeled the worse case release scenario as a total release of one 55-gallon drum with an approximate weight of 450 pounds of TDI. Using EPA approved model, RMP*Comp, the results of the consequence analysis estimated the distance to the toxic endpoint to be 0.1 miles. The IPG facility is located in a fairly remote, industrial area, the 0.1 mile radius of impact does not include any public receptors. The facility has access restrictions to the public such as a fully fenced site, security guard, and identification badges must be obtained before entering the area. 3.0 OFFSITE CONSEQUENCE ANALYSIS The modeled results of the offsite consequence analysis (OCA) performed for the process at IPG indicates that it is eligible for Program 1 level. The following worst-case release scenario is offered. 3.1 Worst-Case Release Scenario A worst-case release is defined by Part 68 of Title 40 of the Code of Regulations as the release of the largest quantity of a regulated substance from a single vessel or process line failure that results in the greatest distance to endpoint. The distance to the endpoint is the distance a toxic vapor cloud from an accidental release of TDI will travel before dissipating to the point that serious injuries from short-term exposures will not occur. The RMP* Comp model uses the three following assumptions to calculate the distance to end point: 7 Wind speed of 1.5 miles per hour, 7 Designated stability class F, and 7 A temperature of 770 Fahrenheit. IPG has the potential to store a total 30,000 pounds of TDI at one central location. The TDI is received and stored in 55-gallon drums weighing approximately 450 pounds each. Using the worse-case release definition, the RMP* Comp model, and the data elements shown in Table 1, the estimated distance to endpoint is a 0.1 miles radius with the center at IPG's warehouse location. A graphical representation of the area affected is shown in Figure 3. TABLE 1 WORST-CASE RELEASE SCENARIO DATA ELEMENTS Data Element Chemical Name Toluene diisocyanate (unspecified polymer) CAS No. 26471-62-5 Scenario Worst-Case Release Quantity released 450 pounds Release area 20,000 square foot building Toxic endpoint 0.0070 mg/L Distance to endpoint 0.1 miles Since the toxic distance to endpoint of 0.1 miles does not affect any public receptors and the effects on people beyond the endpoint are not considered to be severe enough, IPG is eligible for Program 1.No additional action needs to be taken under the RMP rule. 4.0 FIVE-YEAR ACCIDENT HISTORY IPG has not, within the last five years, had any release of TDI at its facility. 5.0 PREVENTION PROGRAM IPG policies dictate that all reasonable steps be taken to insure the safety of its employees and environment. Every employee respon sible for handling TDI is trained in accordance with Occupational Safety and Health Administration (OSHA) regulations, specifically 29 CFR 1910.120 (Hazardous Waste Operations and Emergency Response) and the National Fire Protection Association (NFPA) Standard 472 (Professional Competence of Responders to Hazardous Materials Incidents). These employees receive the 40-hour Hazardous Material training annually. IPG has coordinated with the appropriate local responders if an emergency were to occur. 6.0 Risk Management Plan |