West Coast Distribution Center - Executive Summary |
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General Executive Summary for Chemical Distribution and Warehousing Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Bayer, Polyurethane Division are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the storage and distribution processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with local Fire Department which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass closed container Distribution of chemicals that serves the plastics, polyurethane, dyes and pigments industries. We have 1 regulated substance present at our facility. This substance, unspecified monomer of toluene diisocyanate, is used as a reactant in the manufacturing of flexible polyurethane foams and other elastomers. The maximum inventory of toluene diisocyanate at our facility is 625,400lb. This inventory is located in tow separate processes. A bulk storage tank inventories 305,300 lbs, while a warehouse storage area for drummed material inventories 320,000 lbs of toluene diisocyanate. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To evaluate the worst case scenarios, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance Equations and Tables. The following paragraphs provide de tails of the chosen scenarios. The worst case release scenario submitted for Program 1 toxic substances as a class involves a catastrophic release from the bulk storage tank. The scenario involves the release of 305400lb. of toluene diisocyanate in a liquid form, which evaporates at a rate of 0.02 lbs./min in excess of 60 minutes. Passive mitigation controls such as dikes and sumps are also taken into account to calculate the scenario. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.01 miles is obtained corresponding to a toxic endpoint of 0.0070 mg/L. The worst case release scenario for the warehouse process involves the release of a drum of toluene diisocyanate onto the loading dock area of the warehouse. The release of 550 pounds of material in liquid form evaporates at a rate of 0.002 lbs./min. At this evaporation rate, the spilled release exceeds 60 minutes duration. Passive mitigation controls are not taken into account for this scenario. At Class F atmospheric stability and 1.5 m/s windspeed, the toxic endpoint of 0.0070 mg/L extends to 0.06 miles. No alternative release scenario will be submitted for this toxic substance as none is required for Program 1 processes. There are no regulated flammable substances above the threshold quantity at this stationary source; thus a worst case release scenario for flammable substances as a class is not submitted. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under California State Accidental Release Program, which mimics 29 OSHA 1910.119. This facility was designed and constructed in accordance with the American Society of Mechanical Engineers Code for Unfired Pressure Vessels Section VIII, 1968 Edition and the American National Standards Institute Code B31.3. Maintenance, inspections, and repairs are performe d based on the concepts provided in the American Petroleum Institute Recommended Practice for Pressure Vessel Inspection Standard, 510, sixth edition, June 1989. All materials are stored in containers that meet or exceed the Federal Department of Transportation (DOT) requirements. The closed containers are stored in accordance with the National Fire Protection Agency (NFPA) codes. Containers holding material are inspected for integrity when pulling the order for shipment and during the process of loading. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Bayer, Polyurethane Division maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identifi ed and controlled efficiently. The methodology used to carry out these analyses is HAZOP and What-If/Checklists. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 5 years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our processes, Bayer, Polyurethane maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Bayer, Polyurethane Division has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating pro cedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed. Mechanical Integrity Bayer, Polyurethane Division carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance activities are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Bayer, Polyurethane Division to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job ta sks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Bayer, Polyurethane Division. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Bayer, Polyurethane Division conducts audits on a regular basis to determine whether the provisions set out under the CalARP rule are being implemented. These audits are carried out at least every 5 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Bayer, Polyurethane Division promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release o f a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Bayer, Polyurethane Division truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the CalARP rule, including information resulting from process hazard analyses in particular. Contractors Our company has 5 full-time contractors to conduct specialized operation, maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Bayer, Polyurethane Division has a stric t policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Bayer, Polyurethane Division has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Bayer, Polyurethane Division carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and servi ced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The seismic assessment was reviewed to determine validity of 1992 assessment in accordance with the Guidance for California Accidental Release Prevention Program Seismic Assessment, September, 1998. This assessment found no significant structural deterioration or structural damage to the facility. No recommendations were made. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 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