Heterene Chemical Co., Inc. - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies The Heterene Chemical Company is committed to protecting the public, employees, and the environment while producing chemicals that are important to industry and providing employment for its employees. This Executive Summary describes the processes that are used at this facility and the precautions that are taken to prevent the escape or release of noxious materials. Facility Description The Heterene plant occupies the area between Vreeland Avenue, 21st Avenue, and East 39th Street, in Paterson, New Jersey, and consists of eleven buildings (eight structures), including administrative offices, two laboratories, two warehouses, and seven processing buildings. One of the processes (ethoxylation) uses two reactors and two regulated chemicals - ethylene oxide and propylene oxide. Although these are reactive, toxic, and flammable materials, special procedures and controls are used in their handling and processing. As a result, there have been no serious incidents involving these materials in fifteen years of operation. Worst-Case Release Scenarios Ethylene Oxide is received in railroad tank cars that are approved by the U. S. Department of Transportation, having capacities up to 24,000 gallons. Propylene Oxide is received in tank trucks that also are approved by the U. S. DOT, having capacities of about 4,000 gallons. It is theoretically possible - but highly unlikely (because of the construction and safety devices) - that a container could rupture, and such an incident would be considered a "worst-case" scenario. To determine the maximum number of persons who possibly could be affected, the U. S. Environmental Protection Agency [USEPA] requires that the consequences of such an incident be determined, as is done in this Registration Report. As a result of the congested area in which the Heterene facility is located, the "worst-case" releases could affect the nearby residents and businesses. The types of effects which are evaluated include toxicity, thermal radiation (from slow combustion), and blast (from rapid combustion). To determine the consequences of the "worst-case" releases, the USEPA "Offsite Consequence Analysis Guidance" is used, together with a census program called "Landview". Among the features which are provided to prevent the occurrence of the "worst-case" incidents are devices to prevent overpressurization of containers, sprinkler protection against fire exposure, excess-flow shutoff valves, full-time attendance by operators during unloading, leakage detectors, remote-controlled shutoff valves, and systems to control temperatures, pressures, container levels, and flows. The USEPA also requires that consequences of "alternative" release scenarios be evaluated, such as leaks from piping or other equipment. With the close control of storage, transfers, and processes, such releases are unlikely and would be stopped promptly. As a resul t, it is unlikely that the public or the environment would be affected. Accidental Release Prevention Programs Operations involving Ethylene Oxide and Propylene Oxide at the Heterene facility are regulated by the "Process Safety Management" standard of the Occupational Safety and Health Administration and by the "Accidental Release Prevention" standard of the U. S. Environmental Protection Agency. To comply with these standards, Heterene follows strict guidelines for operating procedures, training of employees, analysis of processes for potential hazards, preventive maintenance programs, emergency plans, and investigation of incidents, with employee participation in this process safety effort. In addition, the Heterene facility has been involved in the New Jersey Toxic Catastrophe Prevention program since 1989, with annual reviews of the EO and PO processes and with three process-safety audits by an outside consultant since that date. Five-Year Accident History There ha ve been no incidents involving release of Ethylene Oxide or Propylene Oxide in the past five years. The most-recent incident occurred on December 30, 1992, and involved the release of less than one pound of Propylene Oxide from an unloading hose, with no on-site or off-site effects. Emergency Response Program As a part of the NJTCPA program, the Heterene facility has conducted two emergency-response drills every year since 1991. These drills involved the Paterson Police Department, the Paterson Fire Department (which comprises the Local Emergency Planning Committee), as well as employees who are trained to recognize and respond to the simulated emergency situation and to actuate shutdown and other protective systems. Annual tours are arranged for members of the Fire Department, to show the locations of the EO and PO unloading and storage facilities and fire protection systems. A weather station is maintained on-site, to provide information to local authorities regardi ng the protection of occupants of residences and business establishments in the downwind direction. Planned Changes to Improve Safety Although there have never been any discharges from the overpressure-protection devices on the two ethoxylation reactors, installation of a "catch tank" to receive any such discharges is planned. Also planned is installation of an improved scrubber to absorb EO and PO from process vents, to replace the existing scrubber. Together with the improvements that have been made to the EO and PO processes over the past ten years, these improvements would provide the continued safe operation and protection of the public that are warranted for this location. |