Valspar Coatings - Chicago Facility - Executive Summary |
|
Accidental Release and Emergency Response Policies It is Valspar's policy to operate its plants in a manner which protect its employees, the public, and the environment. It is our policy to adhere to all applicable federal, state and local laws. The Valspar Chicago facility has a detailed, practiced Emergency Action Plan that is utilized to respond to any accidental release. Facility Description The Valspar Chicago Facility manufactures industrial floor coatings and coatings resin. The manufacturing process uses toluene diisocyanate as a raw material. The facility stores toluene diisocyanate in 2,100 pound steel, pressure resistant cylinders and the maximum amount on site at one time is eight cylinders (16,800 pounds). The cylinders are stored inside the manufacturing building on the lower level. Only one cylinder is used in the manufacturing process at any given time. This process area is surrounded by a dike, which has sufficient capacity to hold the entire contents of t he cylinder in the unlikely event of a release. Worst Case Release Scenario As required by the RMP regulation, the worst case release scenario was calculated by assuming the entire contents of the largest container were released. A loss of the contents of one cylinder in the cylinder unloading operation was chosen as the worst case release scenario. This scenario is very unlikely due to the design of the storage cylinder. According to EPA guidance for calculating the consequence of a toluene diisocyanate release, the distance to endpoint for the release of 2,100 pounds was calculated to be 65 feet. The EPA has determined that toluene diisocyanate does not pose a threat to the public beyond this distance. There are no public or environmental receptors located within this distance. General Accidental Release and Chemical Specific Prevention Programs. The Chicago Facility has implemented the OSHA Process Safety Management Standard which is a systematic method of preventing accide ntal releases and complies with EPAs accident prevention rule. As such, the facility has completed a detailed analysis on the process to ensure the safe use and operation of the applicable equipment. Numerous safeguards are in place and include Operational Procedures, manual and automated control systems, safety interlocks, and other accepted good engineering and industry practices. The facility uses both procedural as well as technological systems to ensure safe handling of toluene diisocyanate. The cylinder is constructed of 3/16" 100 psi rated steel and meets all of the Department of Transportation container specifications for shipment on highways. The transfer system is engineered to prevent toluene diisocyanate from leaking. There are specific procedures for changing a cylinder. Five Year Accident History The Chicago Facility has never had an accident involving toluene diisocyanate that resulted in injuries, property damage or environmental releases. Emergency Respons e Program In the event of an emergency involving toluene diisocyanate , we will immediately notify the Chicago Fire Department and rely on their expertise to handle the situation. The fire department has a well-trained response team. City of Chicago agencies, including the Chicago Fire Department, inspect the facility on a regular basis and are familiar with our processes. We have contracted with a qualified emergency response firm to aid in the cleanup of a release. Planned Changes to Improve Safety We have an ongoing and continuing process to update and review our manufacturing process for safety considerations. |