Polycoat Products - Executive Summary

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RISK MANAGEMENT PLAN - Polycoat Products 
Polycoat Products, a division of American Polymers Corporation, has established a risk management plan according to EPA's regulations (40 CFR Part 68) for the TDI Transfer System to enhance its already existing safety programs.  Polycoat Products is extremely cautious in the handling of all chemicals and is very diligent about safety for its employees and its neighbors.  Polycoat Products staff is well trained and utilizes modern equipment to provide safeguards.  The TDI Transfer System, that contains the regulated substance Toluene Di-Isocyanate (TDI), is used for supplying TDI to the polymer production reactors in the process area.   
Accidental Release Prevention and Emergency Response Policies 
Polycoat Products has an emergency response plan in effect to handle potential emergency situations at this facility.  This plan was designed to meet the following objectives: 
1.) To save lives. 
2.) To minimize and avoid injuries 

3.) To protect the environment. 
4.) To minimize property damage. 
Key elements of the Emergency Response Plan include specific steps that Polycoat Products management expects of its employees to take to protect health of the employees and the neighbors.  The plan includes key phone numbers and contact points, vicinity and evacuation maps, plans for evacuation, fire, injury, earthquake, chemical spill, and health hazards.  
Stationary Source and Regulated Substance 
The TDI Transfer System consists of a double walled storage tank, a transfer pump, a bank of scrubbers that are used during the filling operation, piping and valves.  TDI storage tank is designed for truck and marine transport like a containerized cargo.  Therefore, it includes features to enhance its ruggedness.  The tank is used as a stationary tank at this site.  All piping attached to the tank, penetrate tank boundaries from the top.  This, in addition to the double wall feature, provides an added safety against spill 
age of tank contents.   
TDI is used in small quantities in the reactors to produce polymers.  Transfer is accomplished via a transfer pump that is controlled automatically by a flow meter.  The operator sets the desired quantity in the automatic control unit which then transfers the desired amount to a reactor.  
Hazard Assessment Summary 
Worst Case Release Result Summary 
Scenario Description: It is assumed that the entire content of the storage tank when it is filled to 90% of capacity is released.  Per the instructions of the regulation, the release is postulated to occur in 10 minutes.  Since the vessel is located inside a building, passive mitigation measure was incorporated into the calculations.  The contents of the vessel will collect in the bermed area around the storage tank.  It must be noted that the boiling point of TDI is very high and therefore very little TDI will volatilize from the spilled pool.  The most pessimistic meteorological conditions were used as specified  
in the regulation.  The methodology included in EPA's RMP Offsite Consequence Analysis Guidance was used to determine the maximum downwind distance to 1 ppm.  The result shows that offsite areas may be affected. 
Alternative Release Result Summary 
Scenario Description: Several alternative scenarios were considered as possible to occur.  These scenarios included a range of spills from the transfer pipes or the pump.  In all cases, because of the high boiling point of this material, none of the scenarios would lead to adverse effects (i.e., TDI concentration above 1ppm) outside the site boundaries.   
Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
Polycoat Products has implemented a prevention program to manage the safety aspects of the TDI System.  The program includes written procedures for management of change, incident investigation (includes near miss), training, procedures development and program audit.  Written procedures are developed as part of th 
is program that specify the steps for every task undertaken related to the TDI system. 
Five Year Accident History 
There have been no releases of TDI at this facility in the past 5 years that had lead to an injury, fatality or environmental impact. 
Planned Changes to Improve Safety 
Several management system improvements are being considered and implemented as a result of the technical studies done in the course of the development of the RMP Program.  These improvements include several administrative changes that address specific practices and procedures regarding TDI delivery, training and other tasks related to the operation of the system.  In addition, as a result of the seismic analysis, improvements are being considered for bracing system piping.
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