Dart Polymers, Inc. - Executive Summary |
|
EXECUTIVE SUMMARY 1. Accidental Release Prevention and Emergency Response Policies n-Pentane is used as a raw material in the manufacturing of expandable polystyrene at Dart Polymer, Inc.'s Owensboro, Kentucky facility. n-Pentane is listed by the U.S. Environmental Protection Agency in the Chemical Accident Prevention Provisions (40 CFR 68) as a regulated substance and therefore is subject to the regulations and their requirements. The same properties that make n-pentane valuable as a raw material to our process make it necessary to observe certain safety precautions while handling it in order to prevent unnecessary human exposure, reduce the threat to health and safety of the workers, and to reduce the threat to nearby members of the community. Dart Polymers' accidental release prevention includes the observation and practice of all Federal and State rules and regulations applicable to n-pentane. Safety depends on the manner in which n-pentane is handled, training of personnel in safe handling procedures, and on the safety devices inherent in the design of the Dart Polymers facility. All employees are expected to understand their role in developing and implementing the plan and to diligently adhere to its provisions. The emergency response policy of Dart Polymers at the Owensboro facility is based upon the safety of the employees and the community. 2. Facility and Regulated Chemical Description The primary products of the Dart Polymers facility are polystyrene resins and expandable polystyrene. n-Pentane, a regulated substance, is used by the impregnation process for manufacturing expandable polystyrene and is present in a quantity greater than its 10,000-pound threshold. Two underground storage tanks supply the impregnation process. When necessary a railcar is used to refill the storage tanks. A third tank stores reclaimed pentane from the pentane recovery system. Access to the n-pentane tanks and process area is restricted to authorized Dart Polymers employees, authorized management personnel, and authorized contractors. Because the n-pentane used at Dart Polymers is subject to OSHA's Process Safety Management regulations, it meets the criteria for Program 3. 3. Worst-Case and Alternative Case Scenarios Worst-Case Scenario: The worst-case scenario for n-pentane is the failure of a 30,000-gallon railcar tanker in the unloading area. Vapors from the liquid spill are assumed to find an ignition source and result in an explosion as per EPA's offsite consequence guidance (ten percent of the propane released is assumed to participate in the explosion). This worst-case scenario has the potential to result in offsite consequences on public receptors at the offsite endpoint of 1.0 psi overpressure. Alternative Case Scenario: The alternative case scenario considers a release occurring at the unloading station due to either a sampling error or an unloading connection leak. Because the unloading station is manned at all tim es during unloading and sampling, rapid operator response would limit the release to no longer than one minute in duration. The resulting leak was assumed to cause a pool fire when ignited. This pool fire was identified as having the potential to result in an offsite impact distance that could reach a heat of radiation equivalent to 5 kilowatts per square meter but would be unlikely to affect any nearby public receptors. 4. Chemical Accident Prevention Program Dart Polymers complies with EPA's Chemical Accident Prevention Program rules for n-pentane. All elements of the Chemical Accident Prevention Program requirements under Part 68 have been developed and implemented for n-pentane. The n-pentane equipment was designed to all applicable codes and standards using good engineering practices. A process hazard analysis was conducted on April 16, 1996 using the "What-If" method and all identified problems are being addressed. Written operating procedures associated with all facets of n-pentane storage, handling, and transfer are in place. All persons working with n-pentane or n-pentane containing equipment have been trained on operating procedures and understand the consequences of deviation from the procedures. A mechanical integrity program is in place for n-pentane equipment and operations. 5. Five-year Accident History No accidental releases of n-pentane have occurred at Dart Polymers within the past five years. 6. Emergency Response Program Dart Polymers has trained employees for emergency response and maintain a written emergency response plan. This plan is coordinated with the Daviess County (Kentucky) Emergency Management Agency, the Owensboro Fire Department, and Owensboro Mercy Health Systems. The emergency response plan includes procedures for notification of the fire department and notification of any potentially affected neighbors. All emergency responders including employees and offsite emergency and fore personnel have copies of th e emergency response plan and are familiar with its use from proactive drills. 7. Planned Changes to Improve Safety Dart Polymers' safety program is dedicated to continuous improvement and proactive planning. This program includes the promotion of internal communication and safety awareness among employees, and improved communications with the Owensboro Fire Department, Owensboro Mercy Health Systems and Daviess County Emergency Management Agency. |