PBI/Gordon Corporation Plant - Executive Summary |
|
Dimethylamine is the only chemical used by PBI/Gordon, which is listed under RMP. It is received in single rail cars, which are double-walled with automatic check valves. The unloading system is maintained and upgraded as needed, based on annual reviews by on-site and off-site auditors. Dimethylamine is flammable, and all precautions are taken to prevent any type of problem from occurring. Employees are very conscientious in handling this material, to protect themselves, the plant, and the surrounding area. PBI/Gordon has a written unloading and handling procedure for the unloading of dimethylamine (DMA). This includes a Job Safety Analysis, unloading checklist, and materials specifications. Emergency response actions are reviewed and discussed annually, and employees responsible for DMA unloading have an opportunity for input regarding emergency response. Only those employees specifically trained for DMA unloading and emergency response procedures are allowed in the area at th etime of unloading. The worst-case scenario (required under the RMP) assumes holding tanks are empty, and a 120,000 lb. rail car is on the siding, ready for off-loading. It also assumes only passive mitigation. The car ruptures, due to a tornado, earthquake, or other unpredictable event, and the entire contents are released to the atmosphere within a ten-minute period. A vapor cloud is formed which would remain sufficiently concentrated for an explosion involving at least ten percent of the DMA, after moving approximately 1/4 mile downwind. The alternative release, or more likely scenario, assumes a leaking valve. If it took as long as three hours to correct the problem, the maximum amount of material released would disperse to less than explosive concentration within 26 feet of the release point. The computer model used to obtain data for both the worst-case and alternative scenarios noted that vapor clouds of less than 1000 pounds would be very unlikely to explode. PBI/Go rdon believes correction of such a problem would require significantly less than 3 hours, and would pose no danger to off-site locations. Well-trained employees, automatic and manual shut-offs, a water drench system over the unloading area and a containment area around the tanks would all contribute to prevention of a vapor cloud. Guard service after-hours is further insurance against an event presenting danger to PBI/Gordon or the public. There have been no releases in the past five years. If there was an emergency involving DMA, employees or off-site personnel would respond appropriately, depending on the extent of the release. If the leak could not be repaired quickly, response could include evacuation of the plant site, and possibly sheltering in place for residents and businesses within the determined danger zone. Local agencies would be notified, including the Wyandotte County LEPC, the Fire Department, Police, and HazMat responders in the event of a release that might t ravel off-site. The LEPC has made arrangements to notify the public through emergency broadcasts and the weather alert system. Changes to improve safety of this and other operations at PBI/Gordon are made as annual safety audits identify a need. Currently, the only proposed change is in the type of hoses used for off-loading. This will occur when the next replacement is scheduled. PBI/Gordon is an employee-owned corporation, and many of the employees live in Wyandotte County, and work there. It is in the best interests of all involved to continue to work safely and improve processes continuously. |