DEGESCH AMERICA INC - Executive Summary |
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EXECUTIVE SUMMARY A. DEGESCH AMERICA INC.(DAI) MANUFACTURES METAL PHOSPHIDE FUMIGANTS,PHOSTOXIN AND DEGESCH MAGTOXIN SPOT FUMIGANT. DAI ALSO IMPORTS METAL PHOSPHIDE FUMIGANTS. ALL DAI FUMIGANT PRODUCTS ARE CLASSIFIED AS RESTRICED USE PESTICIDES. ALL DAI PRODUCTS ARE IN FULL COMPLIENCE WITH ALL EPA MANDATES FOR PESTICIDE PRODUCERS. DAI MAINTAINS A CLEAN, MODERN AND EFFICENT MANUFACTURING FACILITY. DUE THE NATURE OF THE PROCESSES AND CHEMICALS USED AND PRODUCED, GOOD HOUSE KEEPING PROCEDURES AND PREVENTIVE MAINTENANCE SCHEDULES ARE STRICTLY ADHERED TO.THESE PROCEDURES PROMOTE A SAFE WORK PLACE, INSURES MINIMAL EXPOSURE RISKS TO DAI EMPLOYEES AND THE COMMUNITY SURROUNDING OUR PRODUCTION COMPLEX. DAI'S EMERGENCY RESPONCE POLICY IS SPECIFIC FOR EACH MANUFACTURING PROCESS AREA. THESE POLICIES INCLUDE EMPLOYEE TRAINING, DIALOG WITH AND COORDINATION WITH THE LOCAL AUGUSTA COUNTY LEPC AND FIRE DEPARTMENT. B. THE PROCESS COVERED BY THIS RMP IS THE MANUFACTUREING OF AMMONIUM CARBAMATE CAS#111-78-01. THIS PROCESS IS FULLY CONTAINED IN A 5000 SQ.FT. STEEL BUILDING. CONTAINED WITHIN IS A 3000 GAL CAPCITY TANK FOR STORAGE OF ANHYDROUS AMMONIA,CAS#7664-41-7 LIQUIFIED UNDER PRESURE. TANK INSTALLATION AND OPERATION IS PER 29 CFR 1910.110 STANDARDS. THE TANK IS FILLED INACCORDANCE WITH SECTION 1910.111(II)(ii) 87% CAPACITY OR 13,387 LBS. AMMONIA CARBAMATE IS MANUFACTURE FIVE (5) MONTHS PER YEAR. THE PROCESS IS OPERATED 24 HR/DAY, FIVE (5) DAYS /WEEK. THIS PROCESS IS ELECTONICALY CONTROLLED AND PHYSICALLY MONITORED WITH VISUAL INSPECTIONS EVERY 60 MINUTES,TO INSURE PROPER OPERATIONAL PARAMITERS AND SAFETY SYSTEMS ARE FUNCTIONING. DURING THE MANUFACTUREING PROCESS OUR PHYSICAL INVENTORY OF ANHYDROUS AMMONIA WILL FLUCTUATE BETWEEN 1000 LBS AND 13387 LBS. WHEN THE PROCESS IS NON-OPERATIONAL AMMONIA INVENTORY IS MAINTAINED AT 1500 LBS +/- 10% TO MINIMISE POTENCIAL ACCIDENTAL RELEASES. C. DAI'S OFF SITE COSEQUENCE ANALYSIS ARE PRESENTED TO REFLECT FULL OPERATIONAL INVENTORIES FOR THE WORSE CASE SCENARIO AND THE ALTERNATE. ALL SCENARIOS WERE PREFORMED USING EPA-COMP CD CONSEQUENCE ANALYSIS. THE WORSE-CASE SCENARIO REPRESENTS A TOTAL LOSS OF 13,387 LBS ANHYDROUS AMMONIA,LQUID DURING THE PRODUCTION PROCESS FOR AMMONIAM CARBAMATE. THE RELEASE OF THE LIQUID AMMOMIA WOULD BE CONTAINED INSIDE THE PRODUCTIONS FACILITY, AN ENCLOSED SPACE WITH DIRECT CONTACT TO THE OUT OF DOORS. USING THE EPA'S ASSUMPTIONS THE ERPG-2 DISTANCE TO TOXIC END POINT OF 1.0 MILES WITH AN ESTIMATED POPULATION POTENTIALLY AFFECTED OF 3000 RESULTED. THE ALTERNATE SCENARIO, AGAIN USING THE EPA'S ASSUMPTIONS, INVLOVES THE LOSS OF 4,764 LBS OF LIQUID AMMONIA DUE TO A RUPTURED PROCESS FEED LINE. AGAIN, THE LIQUD AMMONIA WOULD BE CONTAINED INSIDE THE PRODUCTION FACILITY. THE ERPG-2 TOXIC ENDPOINT WAS LESS THAN 1/10TH MILE. THE ESTIMATED POPULATION POTENTIALY AFFECTED OF 200 RESULTED. D. DAI'S ACCIDENTAL RELEASE PREVENTION PROGRAM FOCASES ON THE FOLLOWIING AREAS: * TRAINING AND EXPERENCED PROCESS OPERATORS *PREVENTIVE MAINTENANCE AND REVIEW OF OPERATING PARAMITERS PRIOR TO AND . DURING INITAL PROCESS START UP *WEEKLY INSPECTION OF ALL FEED LINES AND CONNECTIONS DURING HARVEST OPERATIONS *HOURLY VISUAL INSPECTIONS OF ALL OPERATING CONTROLS *PREVENTIVE MAINTENANCE PREFORMED AT SHUT DOWN *ACCURATE MONITORING OF INVENTORY LEVELS VERSES PRODUCTION THROUGH PUT AT HARVEST E. NO ACCIDENTAL DISCHARGES OR RELEASES OF LIQUID ANHYDROUS AMMONIA HAVE TAKEN PLACE IN THE PAST FIVE (5) YEARS OF PROCESS OPERATION. F. DAI'S EMERGENCY RESPONCE PLANS ARE PROCESS/FACILITY SPICIFIC AND ARE COORDINATED WITH THE LOCAL LEPC AND FIRE DEPARTMENT. THE PLANS PROVIDE FOR POTENTIAL PROBLEM AREAS, ALSO FOR THE COORDINATION OF DAI PRESONNEL AND COMMUNITY RESOURCES FOR EMERGENCY R ESPONSE ACTION. THESE PLANS ALSO DEFINE LAND USE AND POTENTIAL AT RISK POPULATIONS WITH IN 1/2 MILE AND ONE (1) MILE RADIUS OF THE FACILITY. G. 1999 YEAR END SHUT DOWN AND REVIEW HAS IDENTIFIED THE NEED FOR AN ADDITIONAL MANUAL SHUT OFF VALVE ACCESSED FROM OUTSIDE THE STRUCTURE. THIS VALVE WILL BE INSTALLED PRIOR TO THE 2000 YEAR PROCESS RESTART. THE INSTALATION OF THIS VALVE WILL FACILITATE SHUT DOWN OF THE PROCESS WITH OUT ENTERING THE STRUCTURE IN THE EVENT OF PROCESS FAILURE. |