PMC Specialties, Inc. - Executive Summary |
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EXECUTIVE SUMMARY FOR PMC SPECIALTIES, INC. 1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES This facility handles isobutylene (IB) which is a member of the family of materials called liquefied petroleum gases (LPG). This material is considered to be hazardous by the EPA. The same properties that makes an LPG valuable as a fuel and chemical feedstock also makes it necessary to observe certain safety precautions in its handling. These precautions are necessary to prevent human exposure, to reduce the threat to our co-workers and to nearby members of the community, and to eliminate the hazard of fire and explosion. It is our policy to adhere to all applicable Federal and State rules and regulations. Safety depends upon the manner in which we handle Isobutylene, combined with the safety devices inherent in the design of this facility and combined with the safe handling procedures that we use and the training of our personnel. Our emergency response program is bas ed upon the NPGA's LP-Gas Safety Handbook, "Guidelines for Developing Plant Emergency Procedures" and "How to Control LP-Gas Leaks and Fires", and Isobutylene handling information as supplied by Isobutylene manufacturers. The Isobutylene storage tank and its auxiliary equipment was designed and constructed in accordance with NFPA-58. The facility's emergency response plan includes procedures for notification of the local fire authority, local emergency response services and any potentially affected neighbors. 2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES The PMC Specialties Group, Fords facility, manufactures antioxidants and phenolic resins. The antioxidants Butylated Hydroxy Toluene (BHT) and Mono Butyl Para-Cresol (MBPC) are produced by reacting Para-Cresol with Isobutylene. The BHT is then washed, filtered, dried, and packed in drums, bags or supersacks. MBPC is futher reacted to form CAO-5, an antioxidant, which is then washed, filtered, dried, ground, and packed in drums , bags or supersacks. The phenolic resins are also produced at the facility by reacting phenol or alkylated phenol with formaldehyde. The resulting resin is dehydrated, solidified, ground, and packed into bags. Phenol is not regulated under 40 CFR 68 (the Risk Management Plan rules). The formaldehyde solutions used at this facility are exempt from the Risk Management Plan rules. The Fords facility operates 24 hours a day, 7 days per week, and employs approximately 75 people. Isobutylene is received by rail car and stored in one storage tank. This facility has equipment for unloading rail cars. Access to the site is restricted to authorized facility employees, management personnel and contractors. The regulated substance handled at this facility is Isobutylene. The maximum amount of Isobutylene that can be stored at this plant is 730,000 pounds. This includes the combined contents of the Isobutylene storage tank and four (4) rail cars. 3.0 KEY OFFSITE CONSEQUENCE ANALYS IS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: 3.1 Worst-case Release Scenario -- Regulated Flammable Chemicals The worst-case scenario for Isobutylene involves the failure of the Isobutylene storage tank while connected to a railcar resulting in a release of 236,500 pounds of material over a 10 minute period that encounters an ignition source. Ten percent (10%) of the released quantity is assumed to participate in the resulting explosion per EPA guidelines. This type of release could result in an estimated distance of 0.5 miles for 1 psi overpressure, impacting public as well as environmental receptors. Public receptors potentially impacted include: 7 commercial and industrial areas. Environmental receptors potentially impacted include: 7 wetlands Modeling was done using RMP-COMP (EPA program). No administrative controls or mitigation measures could be considered for this scenario. In the worst-case event, the population potentially affected (population within the 0.5 mile circle) is 0. This figure was determined by using Land View III Environmental Mapping Software from the U.S. Department of Commerce. 3.2 Alternative Release Scenario -- Regulated Flammable Chemicals The alternative-case scenario for Isobutylene involves the overfilling of the Isobutylene storage tank resulting in a release of 76,500 pounds over a period of 100 minutes that encounters an ignition source. Ten percent (10%) of the released quantity is assumed to participate in the resulting explosion per EPA guidelines. This type of release could result in an estimated distance of 0.2 miles for 1 psi overpressure, impacting public as well as environmental receptors. Public receptors potential ly impacted include: 7 commercial and industrial areas. Environmental receptors potentially impacted include: 7 wetlands Modeling was done using RMP-COMP (EPA program). No administrative controls or mitigation measures could be considered for this scenario. In the worst-case event, the population potentially affected (population within the 0.2 mile circle) is 0. This figure was determined by using Land View III Environmental Mapping Software from the U.S. Department of Commerce. 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS. This facility takes a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: 7 Process safety information (i.e. process technology) 7 Process hazard analysis 7 Operating procedures and safe work practices (including hot work) 7 Training and performance 7 Mechanical integrity 7 Quali ty assurance 7 Management of change (technology and subtle) 7 Pre-startup review 7 Compliance audits 7 Incident investigation and reporting 7 Employee participation 7 Hot work 7 Contractors (safety and performance) 7 Management of change-personnel 7 Emergency planning and response These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and employees are committed to the standard that these management systems set the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5.0 FIVE-YEAR ACCIDENT HISTORY The facility maintains records of all accidents or incidents which occur at the site. There have been no accidents or incidents at our facility involving the release of Isobutylene during the 5-year period proceeding the date of this report 6.0 EMERGENCY RESPONSE PROGRAM We maintain an emergency response plan, which meets all the requirements stated in the RMP rule. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. We have discussed the RMP Plan with the Woodbridge Office of Emergency Management (Local Emergency Planning Committee) and the Fords, NJ Fire Department. A representative of the Fire Department visited this plant in December 1998. The facility is included in the Woodbridge Office of Emergency Management's Basic Operations Manual. 7.0 PLANNED CHANGES TO IMPROVE SAFETY The Isobutylene storage tank and its auxiliary equipment was constructed in 1955 and is in compliance with the NFPA-58 Standard that was in effect at that time. The rail car unloading system was upgraded in 1995, and the facility plans to do further maintenance and upgrade to the most current version of the NFPA-58 Standard. 8.0 CERTIFICATIONS Based on the criteria specified for RMP compliance, the undersigned certifies that , to the best of their knowledge, information, and belief, formed after reasonable inquiry, that the other information submitted in this RMP Plan is true, accurate, and complete. Signature Title Date |