Thetford Corporation - Executive Summary

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7 Introduction: 
 
Thetford Corporation operates a holding tank deodorant blending and bottling operation in Ann Arbor, Michigan.  The facility is located at 7101 Jackson Road in Scio Township.  The facility consists of one building that houses the blending and bottling operation, as well as product development and offices.  Overall, the facility employs 90 full time employees. 
 
Thetford Corp is committed to operating in a manner that is safe for its workers, the public and the environment.  As part of this commitment, Thetford has established a system to help ensure safe operation of the process at this facility.  One component of this system is a risk management program that helps manage the risks at the plant and that complies with the requirements of the Environmental Protection Agency's regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (RMP).  One of the requirements of the RMP rule is to submit a risk management plan describing the risk 
management program at the Thetford facility.  This document is intended to satisfy that requirement and to provide the public with a description of the RMP at the plant. 
 
7 Accidental Release prevention and emergency response policies: 
 
Thetford implements reasonable controls to prevent foreseeable releases of formaldehyde.  These controls include training programs for personnel, programs to help ensure safety in the design, installation, operation, and maintenance of processes at the facility, programs to evaluate the hazards at the plant, equipment to continuously monitor formaldehyde in the mixing area and level sensors to prevent tank overflows. 
 
In the event of an accidental release, Thetford contains the release in a manner that will be safe for workers and will prevent injury to the public and the environment.  Thetford provides response training to its personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with  
the local fire department.  Response activities have also been discussed with the LEPC.   
 
To effectively implement these policies, Thetford established a management system headed by the Vice President of Operations to oversee safety-related activities. 
 
7 Regulated substance: 
 
Formaldehyde is the regulated substance handled in sufficient quantity to be covered by EPA's RMP rule.  It is used in the production of holding tank deodorants.  The finished products are used in the holding tanks of recreational vehicles, boats and portable toilets.  Formaldehyde is received as a 37% solution in water.  The maximum amount of actual formaldehyde allowed in the storage tanks is limited by administrative controls and does not exceed 60,200 pounds.  Within the entire process the maximum amount of actual formaldehyde is 92,000 pounds.   
 
7 Off-site consequence analysis: 
 
Thetford performed an offsite consequence analysis to estimate the potential for an accidental release of formaldehyde to affect  
the public or the environment.  The offsite consequence analysis evaluates a worst-case release scenario and an alternative release scenario.  Thetford does not expect a worst-case release scenario to ever occur due to the controls in place.  The alternative release scenario was selected to help the LEPC improve the community emergency response plan. 
 
The main objective of performing the offsite consequence analysis is to determine the distance to the endpoint (under worst case conditions, the distance formaldehyde could travel before dispersing enough to no longer pose a hazard to the public). When considering the release of formaldehyde, people at the endpoint distance would be able to walk away from the exposure without any health consequences.  At distances less than the endpoint distance, some short-term health effects are possible including irritation of the eyes, nose and throat. 
 
The following summarizes the offsite consequence analysis performed by Thetford. 
 
The worst-case re 
lease scenario for a solution 37% formaldehyde is the release of the entire contents of a 9,000 gallon (30,070 pounds of pure formaldehyde) storage tank within the building.  A concrete diked area contains the formaldehyde in the blending room.  The maximum distance to the toxic endpoint concentration based on the EPA look up tables is 0.19 miles or 1003 feet.   
 
The alternative case scenario for a 37% solution of formaldehyde is the overfilling of a mixing vessel and the spillage of 1000 gallons of solution (3,300 pounds of actual formaldehyde) into the diked area of the indoor mixing room.  Modeling this scenario indicates a toxic endpoint distance of .06 miles or 317 feet.  
 
7 Accidental Release Prevention Program and Chemical-Specific Prevention Steps: 
 
In 1995, Thetford developed and implemented a prevention program for the formaldehyde process to comply with the 13 elements of the OSHA Process Safety Management (PSM) prevention program.  Thetford is in full compliance with the OS 
HA standard.  The EPA RMP rule expands the OSHA PSM to include a focus on protecting the public and the environment.  According to an outside consultant who recently performed a compliance audit, "The Thetford Corporation has conscientiously developed and implemented the PSM program at its facility located in Ann Arbor, Michigan.  The effort expended by all levels of management and labor at the facility to comply with the PSM standard and implement the PSM program is excellent."  The following highlights a few specific steps that are key to the prevention program. 
 
Process Hazard Analysis (PHA)  - Thetford performs process hazard analyses on all mixing processes (formaldehyde and non-formaldehyde) in the building to identify process hazards and generate recommendations that might improve the safe operation of the process.  A PHA committee reviews all recommendations from the PHA.  A schedule of action items and completion due dates are developed by the committee and assigned to individ 
uals with responsibility in the respective area. 
 
Management of Change (MOC) - Thetford's Management of Change (MOC) program ensures that changes made to the system do not alter the safe operation of the system.  The MOC is designed to prevent changes occurring to the system until proper safety reviews, training, material updates, and procedures have been modified to reflect the change.  The only changes that do not have to follow the management of change procedure are "replacement in kind".  
 
Mechanical Integrity - The purpose of the Mechanical Integrity Program is to make certain that the equipment in the process is installed, maintained, operated, inspected and tested to ensure its continued safe operation.  The program is designed to address the specific needs of each type of equipment covered. The Mechanical Integrity Program covers all equipment contained in the chemical mixing and the bottle filling rooms in the facility, including those that handle highly hazardous chemicals an 
d those that do not. 
 
Incident Investigation - Thetford investigates all incidents that resulted in or could have resulted in a release of formaldehyde so that similar accidents can be prevented in the future.  An investigation team is assembled, and the investigation is initiated within 48 hours of the incident.  The results of the investigation are documented, recommendations are resolved and appropriate process improvements are implemented. 
 
Formaldehyde Specific Prevention Steps 
 
Formaldehyde solution is delivered to the facility by offsite vendors.  The formaldehyde solution is pumped directly to storage tanks inside the building.  The formaldehyde vendor supplies formaldehyde solution via a DOT approved tank truck and follows DOT standards when loading the formaldehyde solution to storage tanks.  Workers who perform operations involving formaldehyde receive training annually emphasizing safe handling procedures for formaldehyde developed by Thetford.   Additional precautions are  
maintained with the PSM program.  These include a diked unload area that drains into a holding pit within the building, a Truck Driver Unload Policy that every delivery service must accept and adhere to when unloading at the facility, an unload checklist to double check connections before unloading, a remote emergency shut off to stop the operation in case of failure, preventative maintenance program to avoid failure of equipment during operation, and annual certification of the corresponding Standard Operating Procedure.  
 
7 Five -Year Accident History 
 
Thetford has completed a five-year accident history that indicates no off-site release of formaldehyde has occurred. 
 
7 Emergency Response Programs 
 
Thetford has developed a written emergency response program to help safely respond to accidental releases of formaldehyde.  The emergency response plan includes procedures for the following:   
 
1. Informing the local fire department about accidental releases that could reasonably result in 
offsite consequences  
2. Providing proper first aid and emergency medical treatment to treat accidental human exposure to formaldehyde at the facility 
3. Containing accidental releases of formaldehyde including the use of emergency response equipment 
4. Inspecting and maintaining emergency response equipment 
5. Reviewing and updating the emergency response plan 
 
The facility maintains an emergency response team trained in the above emergency response procedures.  All plant personnel are trained in evacuation procedures.  The plant annually conducts emergency response drills.  The written emergency response plan complies with other federal contingency plan regulations (the OSHA regulations 29 CFR 1910.38(a), 29 CFR 1910.120(a)) and has been directly communicated to local emergency response officials.  The plant maintains a regular dialogue with the local fire chief and the facility provides appropriate information to the fire chief. 
 
7 Planned changes to improve safety 
 
1. A tabletop e 
xercise will be performed for emergency response with the local responding agencies. 
2. Employee emergency response training and drills will continue to ensure employees are familiar with the procedures.
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