Chesterfield Trim Plant - Executive Summary |
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NOTE: The RMP-submit software would not allow certain values to be entered. The correct values are as follows: Section 2. Toxics Worst Case 2.6 Release Rate = 0.0060 lbs/min 2.7 Release Duration = 1,914,000 mins 2.11 Distance to Endpoint = 0 mi (Per our modeling, the concentration of TDI will not exceed the endpoint anywhere on site.) SUBMISSION [40 CFR 68.150] The Ford Motor Company owns an automotive parts manufacturing facility in Chesterfield Township, Michigan, that is operated by Visteon Automotive Systems and subject to the requirements of the Chemical Accident Prevention provisions of 40 CFR Part 68. The following Risk Management Plan (RMP) was prepared in accordance with 40 CFR Part 68, using guidance obtained from the United States Environmental Protection Agency and the judgement of environmental professionals. EXECUTIVE SUMMARY [40 CFR 68.155] ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES [40 CFR 68.155(a)] The Chesterfield Trim Plant stores TDI on -site in quantities in excess of 10,000 pounds. The Chesterfield Trim Plant minimizes the risks associated with its TDI system by: 1. Implementing work practices that minimize releases during the delivery and storage of TDI, 2. Implementing inspection and corrective action procedures established under the Chesterfield Trim Plant's Environmental Management System (ISO 14001) program, 3. Employee training, 4. Limiting access to the TDI storage area, and 5. Planning and training for response to an emergency. THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED [40 CFR 68.155(b)] The Chesterfield Trim Plant is an automotive parts manufacturing facility producing a variety of products for Ford Motor Company. The storage and dispensing of TDI at the Chesterfield Trim Plant is limited to one 8,800-gallon liquid TDI storage tank and its associated system. The storage capacity of the tank is limited by administrative controls to 85 percent by volume or 7,480 gallons (75,000 pounds). The TDI is used in the manufacturing of foam products. WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS [40 CFR 68.155(c)] Three release mechanisms were evaluated to define the worst-case release scenario. The mechanism selected as the worst case release is the release of the entire contents of the tank within its diked area inside the building. This mechanism was selected to produce the worst case release scenario since it produces the greatest distance to the highest concentration, however, none of the mechanisms evaluated produced concentrations of TDI that reached the toxic end point at any location within or beyond the Chesterfield Trim Plant property line. Therefore, the Chesterfield Trim Plant is a Program 1 facility. The Chesterfield Trim Plant minimizes the possibility of any release through the procedures, training, and inspections established under its ISO 14000 Environmental Management System. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM [40 CFR 68.155(d)] The Chesterf ield Trim Plant has developed and uses routine maintenance and operational controls to prevent accidents. The established work practices for the delivery and storage of TDI at the Chesterfield Trim Plant outline the methods of transferring TDI from the delivery vessel to the storage tank and storing TDI that minimize releases. Each employee with job responsibilities associated with the storage, handling or use of TDI is thoroughly trained or otherwise deemed competent in the TDI-related work practices and procedures relevant to their responsibilities. The inspection and corrective action procedures at the Chesterfield Trim Plant will be utilized to ensure that the structural integrity of the TDI system and the adequacy of the security measures associated with the system are properly maintained. FIVE-YEAR ACCIDENT HISTORY [40 CFR 68.155(e)] The Chesterfield Trim Plant has never had a reportable accidental release of TDI. EMERGENCY RESPONSE PROGRAM [40 CFR 68.155(f)] The Chesterfiel d Trim Plant has personnel trained to respond to the on-site effects of accidental TDI releases. If off-site reponse is necessary the Chesterfield Trim Plant coordinates with the Chesterfield Fire Department and other emergency response agencies. |