ChemRex, Inc - Executive Summary |
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ChemRex, Inc. of Brighton is a new facility that started production in December of 1997. It has the primary activity of producing adhesives and caulks for use in the construction industry. Toluene diisocyanate is the regulated substance stored and used within the plant. TDI is received in 45,000-pound tank trucks and transferred to a 64,000-pound holding tank within the building. The handling of TDI in ChemRex's processes is completely computer controlled. Prior to use in manufacturing, TDI is pumped from the bulk storage tank into one of three 2350-pound capacity "day" tanks. TDI is then pumped from the "day" tanks to mixer heads in the intermediate area, reacting and consuming the material. The worst-case release scenario would involve failure of tank truck or transfer hose integrity with the release of the entire truck contents onto the offloading area outside the building. Using the RMP OCA Guidance document, this 45,000 pound unmitigated spill would release 0.25 lbs./min. of TDI into the atmosphere and travel 0.31 miles before reaching the toxic endpoint. ChemRex has specific standard operating procedures and training in the offloading of tankers to bulk storage. The TDI offloading SOP specifies that a trained ChemRex employee wearing proper PPE will be present during the entire procedure, including transfer hose hookup, product transfer, offload, and removal of the transfer hose. Any leak or rupture will be observed and proper steps taken to shut down transfer to minimize TDI loss. An Isocyanate emergency stop is located at the offload station that automatically stops the offload operation when pressed. ChemRex has had no accidental releases at the Brighton facility. ChemRex has a comprehensive contingency (emergency response) plan that includes procedures for chemical spills/releases, medical emergencies, natural disasters, and environmental issues. It identifies the Emergency Coordinator, Team Leaders, and Emergency Response Team members and t heir responsibilities and training. It also has procedures for coordinating response with local response agencies. 1999 budget improvements include $4000 towards installing a vent in the TDI bulk storage room that would minimize the build-up of TDI vapors and decrease the potential for release of vapors into other areas of the facility in the event of a small leak within the room. |