ADCO PRODUCTS, INC. - Executive Summary |
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RISK MANAGEMENT PROGRAM EXECUTIVE SUMMARY FOR ADCO PRODUCTS, INC. ADCO Products, Inc., a wholly owned subsidiary of ADCO Global, Inc., is a manufacturing plant located in Michigan Center, Michigan. ADCO Global, headquartered in Raleigh, North Carolina, is a manufacturer of adhesives and sealants serving customers worldwide with automotive and construction materials. ADCO Global has three other operating subsidiaries: Ruvan, Inc. Pro-Form, Inc. and Tioga Coatings Corporation. RuVan and Pro-Form operate plants in Evansville, Indiana, and Tioga Coatings operates a plant in Rockford, Illinois. It is the world wide policy of ADCO Global to design, manufacture and distribute its products and to handle and dispose of materials throughout their life cycle in a manner that protects the environment and safeguards employees, customers and the public from unacceptable risk. ADCO participates in the Responsible Care program of the Chemical Manufacturers Association. The Community Awar eness and Emergency Response Code of Responsible Care brings chemical plants and local communities together through communications and cooperative emergency planning. The Process Safety Code of Responsible Care is designed to prevent fires, explosions and accidental chemical releases. The code requires safety audits, inspection and maintenance programs, and safety training for employees and contract workers. Facilities are encouraged to listen to the concerns of the community and to consider these concerns when designing and implementing process safety systems. ADCO is housed in a building of approximately 172,300 square feet in Michigan Center, Michigan. The building is situated on a 43-acre parcel five miles east of the city of Jackson on the banks of the Grand River in Jackson County's Leoni Township. Boundaries are Falahee Road on the west, Page Avenue on the north, Fifth Street on the east and Flansburgh Road on the south. Within a half mile of the facility, there are an es timated 1,000 people and 50 to 75 small businesses. ADCO is a member of the Jackson Area Manufacturers Association whose purpose is to help guide participating area businesses successfully through regulatory channels. In addition, ADCO provides active support to Jackson County's minority mentoring program. Local high school students are brought into industrial settings over the course of a three-month period and exposed to a variety of occupations. The short-term goal of the program is to encourage the students to stay in school and perhaps pursue college-level coursework. The long-term goal is to return to the industrial environment a skilled worker who also enjoys his work. Other community activities receiving support from ADCO are the Jackson County Hot Air Jubilee, the Grand River Expedition and the Jackson County Grand Prix. ADCO Products also sponsors a scholarship program for children of eligible employees. Annual taxes on the facility of approximately $180,000 help to s upport three community schools. The plant employs approximately 290 production and salaried personnel operating on a three-shift, five-day-a-week schedule. ADCO's products consist largely of butyl rubber compounds and are sold worldwide. These products fall into four major product lines: 1) Adhesives: consisting of specialty glues, tape products, rubber base cements, and hot melt compounds 2) Sealants: consisting of butyl-based, acrylic and urethane caulking compounds 3) Rolled rubber roofing: consisting of various compounds and roofing tapes of many lengths and widths used for splicing, patching or around protrusions on rubber membrane roofing. 4) Acrylic tapes: consisting of various tapes for the automotive and construction industries. The most serious problem that might occur during the production process is a fire or spill of solvent or oil. Several types of oils and solvents are used in the various processes at ADCO. 1) Oils are used in all butyl tape products as well as h ot melt products. 2) Food grade oils are also used in most of ADCO's products 3) Oils and solvents are delivered to the ADCO site by cargo tank trucks. The off-load areas adjacent to the tank farms are sloped and diked to contain potential leaks or spills from the unloading process. 4) Oils are stored in tanks inside the facility; some at ambient temperature and some above ambient temperature. 5) Solvents are stored in tanks in contained areas outside of the facility. 6) Solvents are used in most caulking, urethane and primer applications. 7) All oils and solvents are pumped directly into the processing equipment via above ground piping systems. 8) Solvent tanks have overfill protection. Some have dripless fill connectors. The only RMP regulated substance on ADCO premises is toluene diisocyanate (TDI). Toluene diisocyanate is held in a 3,000 gallon tank in the tank farm located west of the main plant building. This tank is equipped with overfill protection, an alarm system, drip less connectors and internal monitoring. The tank farm area is completely encompassed by a cement dike capable of containing the entire contents of any tank in the tank farm. In case of fire, release of hazardous materials or the need to make an emergency rescue operation, emergency response coordinators and back-ups have been named for all three shifts. Department and shift supervisors are trained in Red Cross CPR and first aid. Emergency response coordinators are responsible for evaluating the specific emergency and notifying the applicable organization whose assistance may be needed: such as the fire department, police department, 911 rescue, etc. Coordinators select and assign personnel to assist in any necessary evacuation, perform rescue operations, provide first aid, control in-coming and out-going pedestrian and vehicular traffic, assist outside emergency personnel as they arrive and provide technical assistance and advice as needed. A rescue squad consisting of va rious plant personnel has been trained in the use of special equipment, rescue techniques, spill containment and first aid to provide in-plant emergency staffing prior to the arrival of any other necessary emergency assistance. Leoni Township Fire Department and Rescue visit ADCO at least annually to review plant operations and to acquaint themselves with on-site emergency equipment. A local hospital is used for all first aid and medical emergency situations. Doctors from the hospital have toured the facility to become familiar with the operations. The off-site consequence for a "worst-case release scenario" at the ADCO site's stationary source was performed for the 2,4-toluene diisocyanate tank. The parameters used for the worst case release scenario were those defined and pre-set by EPA in the RMP Rule for Toxic Liquids. Our worst-case scenario involves the failure of a toluene diisocyanate (TDI) storage tank containing a maximum of 3,000 gallons (30,900 lbs.). Should a TDI t ank experience a complete failure, the TDI would be spilled into a 17.3 ft x 18.75 ft. x 3 ft. high dike. The capacity of the dike is 973 cubic feet while the entire contents of the tank is only 402 cubic feet. As the dike is capable of containing the entire contents of the tank, the level of concern is 31 feet. Therefore, the toluene diisocyanate would not reach any offsite endpoints or public receptors. As a result of these findings, ADCO meets the eligibility requirements for Program 1 status under the RMP Rule and is not required to conduct the less severe "alternative release scenario" analysis. Procedures are in place detailing the steps to be followed to prevent spills when unloading tank trucks. However, potential for spills exists in essentially all plant areas from the over-filling of a tank, breakage in a hose or line, or damage to drums during loading, unloading, or storage. Outside solvent storage tanks are diked to prevent loss of spilled materials from leaking li nes or as a result of a total tank failure. Above ground tanks and lines are inspected monthly for damage or deterioration. There are no underground tanks or transfer lines on site. Plant personnel have been specifically trained to watch for spills and a spill response team has been trained to handle any minor emergencies that might arise from a spill. Emergency eyewash and safety showers have been installed at both tank farms for the protection of delivery drivers and plant employees in case of chemical contact. All employees associated with the unloading, transfer and use of 2,4-toluene diisocyanate are trained in the proper procedures for the safe handling of TDI. When 2,4-toluene diisocyanate is being used in the facility, a chemical specific monitor (MDA isocyanate) is used to monitor the work area for leaks. All employees associated with the use of 2,4-toluene diisocyanate are given complete physicals on a yearly basis. The use of 2,4-toluene diisocyanate is controlled th rough a computer system to minimize any contact or employee exposure. All internal and external piping for this product is welded stainless steel to reduce the potential for leaks. It is worthwhile to note that ADCO has had no accidents as defined in the RMP regulations in the past five years, nor has it ever had an accident of this type since its inception in 1971. Emergency evacuation plans designate two assembly points outside the plant. Each department is assigned to meet at one of the two assembly points. Evacuation maps are located throughout the facility showing emergency exit routes. Various staff members have been assigned responsibility for taking a headcount at the assembly point. Drills to practice this evacuation process are held at a minimum of once a year. The plan also includes shutdown procedures for gas and electrical service into the plant. The site emergency coordinator will notify any needed off-site authorities and initiate any immediate required prote ctive actions. Plans are also in place to coordinate activities with the Leoni Township Fire Department, City of Jackson Hazmat Response Team, Jackson County Health Department, Fire Marshall Division of the Michigan State Police and the Jackson County Board of Commissioners. A national weather alert system has been installed in the security office to warn of severe weather and approaching tornadoes. Other measures being pursued to improve the work environment and employee safety include modifications to major pieces of equipment to improve indoor air quality. A repetitive motion survey has been conducted to determine which operations may need to be modified and which employees are involved in these tasks. Weekly safety meetings are conducted in most departments. Process hazard analyses are conducted on new processes which contain hazardous chemicals. The process hazard analysis for the 2,4-toluene diisocyanate is reviewed each time the process is modified. ADCO recognized t he size and complexity of the computer-related Year 2000 problem and implemented a company-wide initiative to address the issue. The plan encompasses all of ADCO's software applications, processes, and production and facilities equipment, including those having embedded software provided by our vendors. Various aspects of the effort have touched on information systems, production and facilities equipment, products we sell, customers, and suppliers. We continually strive to find new procedures and processes to that will allow ADCO to improve employee health and safety as well as reduce potential environmental risk and community concern. |