ADC - Adrian - Executive Summary |
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Risk Management Plan Executive Summary Anderson Development Company - Michigan Street Plant, Adrian 1. Accidental Release Prevention and Emergency Response Policies Anderson Development Company is strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program that includes design, installation, operating procedures, maintenance, and employee training in the processes at our facilities. It is our policy to implement appropriate controls to prevent releases of hazardous substances. If such a release does occur, our highly trained personnel will respond to control and mitigate the effects of the release. We also coordinate our training and response efforts with the Adrian Fire Department which provides additional emergency response administrative capabilities. 2. The Stationary Source and the Regulated Substance s Handled ADC manufactures a range of specialty chemicals including acrylic resins, urethane resins, and catalysts. We have four hazardous materials in three processes at our ADC-Adrian plant which are subject to the Risk Management Plan regulations. Our main plant on Michigan Street has maximum inventories of anhydrous hydrogen chloride, titanium tetrachloride, and two different forms of toluene diisocyanate which exceed the RMP threshold quantities. 3. The Worst Case Release Scenario and the Alternative Release Scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario. Required offsite consequence analysis for both plants has been performed using the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The worst case release scenario for ADC-Adrian involves anhydrous hydrogen chloride and calls for the release of the maximum inventory of the large six tube trailer tr uck over 10 minutes in gaseous form. Under the most unfavorable atmospheric conditions, the EPA estimates such a release could reach a maximum distance of several miles when 0.03 ppm is used as the toxic endpoint. While toxic concentrations immediately dangerous to life and health during such a worst case scenario would be reached on the plant site, the human health impact of such a release near the toxic endpoint concentration area is chiefly skin, eye, and respiratory irritation. For titanium tetrachloride, the maximum amount which could be involved in an alternative release scenario is the content of one large cylinder over 10 minutes. Carried to the EPA's toxic endpoint of 0.02 ppm under typical atmospheric conditions, a maximum distance a half mile from the release point could be impacted. The alternative release scenario for either form of TDI would involve the maximum contents of a raw material tank truck released over 10 minutes. We estimate such a release would reach less than a hundred feet under typical atmospheric conditions when calculated to the toxic endpoint of 0.007 ppm. The alternative release scenario for anhydrous hydrogen chloride involves the more probable release of a couple hundred pounds over 10 minutes as might happen via a leaking pipe. We estimate such a release under typical atmospheric conditions would reach less than a quarter mile when calculated to the toxic endpoint of 0.007 ppm. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps ADC has taken all necessary steps to comply with the accidental release prevention requirements. Our Adrian facility meets all requirements of State Building Codes and MIOSHA' s Process Safety Management standard for chemical processes, as well as the Community Right To Know notification requirements of EPCRA and TRI. The following sections briefly describe the elements of the accidental release prevention program in place at the ADC-Adrian fa cility. Process Safety Information - Detailed records of process safety information describing chemical hazards, operating parameters and equipment designs are maintained for all processes. Process Hazard Analysis - Comprehensive HAZOP studies are conducted for our chemical processes to ensure that all potential hazards are identified and controlled efficiently. The methodology for these logic analyses is generally a software package of "what if" checklists. The studies are performed by teams of qualified personnel from engineering, safety, management, and operators who are familiar with the operational details of each particular process. The studies are revalidated at intervals of three years or whenever major process changes occur. Any hazard analysis findings are addressed. Operating Procedures - Written operating procedures are maintained for all processes. These procedures cover initial startup, normal operations, temporary conditions, normal shutdown and emergency shutd own. The information is regularly reviewed and routinely followed by process operators. Training - Our comprehensive training program is the basis for certification of the process specific competency of each operator. Refresher training training is provided every three years at the time of PHA reviews. Mechanical Integrity - ADC performs documented maintenance checks on process equipment to ensure reliable operations. Process equipment inspected includes: reactors, storage tanks, piping systems, relief and vent systems, emergency generators and shutdown systems, pumps, and control systems. Maintenance operations are performed by qualified personnel trained and certified in maintenance practices. All identified deficiencies are corrected in a safe and timely manner. Management of Change - Necessary process changes to chemicals, technology, equipment and procedures are made in accordance with methodical written management procedures. Process operators and maintenance personnel are i nformed of and provided training to safely and reliably deal with necessary process modifications. PreStartup Safety Reviews - Whenever startups of new processes or modified processes occurs, a hands on review is conducted to confirm that construction, equipment, operating and maintenance procedures are suitable before equipment is placed into operation. Compliance Audits - Extensive reviews of all compliance aspects of accident prevention programs are performed every three years. Prompt corrective actions are performed upon audit completion. Incident Investigation - Any incident that has resulted in, or could reasonably result in the release of a hazardous substance is promptly investigated. These investigations are undertaken to identify the root cause of each incident as well as to identify any corrective actions to prevent releases from occurring. Employee Participation - Process safety and accident prevention are a team effort. All process employees are included in discussi ons concerning accident prevention issues and to recommend improvements. All process employees have access to all information in the accident prevention program, especially information from process hazard analyses. Contractors - ADC hires numerous area contractors to perform specialized maintenance and construction activities. The safety programs and performance of all contractors are evaluated and continually monitored. All individuals working for contractor firms hired by ADC receive annual safety training from ADC's Safety Department. ADC informs all contractor workers of known potential hazards related to each project's plan of action. All contractors are also informed of emergency response procedures and required to cease working should an accidental release occur. 5. Five Year Accident History There have been no accidental releases of RMP regulated chemicals in quantities greater than one pound from either of ADC's Adrian facilities. 6. Emergency Response Plan ADC has developed a written comprehensive emergency response plan to deal with all emergencies, including the accidental release of hazardous substances. The plan covers all aspects of emergency response including first aid and medical treatment, evacuations, shelter in place, notification of local emergency response agencies and the public, as well as post incident decontamination of affected areas. All emergency response equipment is regularly inspected and serviced. The emergency plan is promptly updated to incude response to any process changes. 7. Planned Changes to Improve Safety ADC strives to continuously improve and update operating procedures, replace or maintain equipment to meet or exceed original specifications or design codes and to develop and implement safety improvement capital projects. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is t rue, accurate and complete. Name: Randy Gibbs Title: Environmental Manager Date: 28 June 1999 |