Schlegel Systems, Inc. - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
At Schlegel Systems, Inc., we are committed to operating and maintaining all of our processes (especially those using hazardous substances including toluene diisocyanate) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:
* A description of our facility and use of substances regulated by EPA's RMP regulation
* A summary of results from our assessment of the potential off site consequences from accidental chemical releases
* An overview of our accidental release prevention programs
* A accident history for accidental releases of chemicals regulated by EPA's RMP rule
* An overview of our eme
rgency response program
* An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our
employees, the public, and the environment
* The certifications that EPA's RMP rule requires us to provide
* The detailed information (called data elements) about our risk management program
STATIONARY SOURCE AND REGULATED SUBSTANCES
Our facility produces polyurethane foam seals for doors, windows and gaskets for use in the electronic industries using a variety of chemicals and processing operations. In our processes, we use toluene diisocyanate (TDI) that EPA has identified as having the potential to cause significant off site consequences in the event of a substantial accidental release:
Toxics Storage Mechanism & Quantity
Toluene Diisocyanate (TDI) 6,000 Gallon Bulk Storage Tank
Our accidental release prevention programs and our contingency planning efforts help us effectively manage t
he hazards that are posed to our employees, the public, and the environment by our use of toluene diisocyanate.
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario:
Worst-case Release Scenario(s) - Regulated Toxic Chemicals, Toluene Diisocyanate (TDI)
A sudden and unexpected loss of the entire contents of the chemical bulk storage tank could conceivable result in a release of up to 45,000 lbs. of TDI. The TDI chemcial bulk storage tank is located inside of our manufacturing building in a separatly ventilated and diked area. The secondary containment system consists of a double
lined dike that is capable of containing all of the contents of the chemical bulk st
orage tank. To prevent a signifcant release of TDI into the air that could potentially affect anyone off-site of our property, the chemical bulk storage tank room can be isolated and all ventilation turned off. In addition there is a sophisticated chemical monitoring
system to alarm in the event of even a trace amount of TDI were to be released. There are no off-site or public receptors that would be impacted by a worst case release scenario of TDI as a result of the systems in place to capture and mitigate the affects of a TDI release.
Alternative Release Scenario(s) - Regulated Toxic Chemicals, Toluene Diisocyanate (TDI)
A sudden and unexpected release of TDI from the discharge pipe on the TDI chemical bulk storage tank could result in up to 100 gallons of TDI to be released. The discharge pipe is located off the top of the TDI chemical bulk storage tank but still within the secondary containment system of the chemical bulk storage tank.
All of the TDI would be contained with
in the secondary containment system and the ventilation system for the room would be isolated to prevent any type of signifcant release of TDI into the air. There are no public receptors or off-site locations that would be impacted by an alternate release scenario of TDI from our facility.
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals including toluene diisocyanate. Our management systems address each of the key features of successful prevention programs including:
* Process safety information
* Process hazard analysis
* Chemical unloading procedures
* Training and emergency response team training
* Mechanical integrity
* Management of change
* Chemical Safety
* Incident investigation
* Employee participation
* Hot work permit program
As part of our prevention efforts, we have implemented the following chemical specific prevention steps:
* All mechanical and electrical systems are checked prior to the delivery and unloading of bulk chemicals.
* A minimum of 2 properly trained Schlegel Employees plus the bulk tank delivery driver are utilized when unloading bulk chemicals.
* All personnel communicate directly using hand held communication devices.
* The inventory of the chemical bulk storage tank is checked both mechanically and electronically to prevent overfilling of the storage tank
* The chemical unloading area is diked in the event of spill or release.
* The chemical unloading connections are labeled, color coded and sized to only fit the hose for unloading of toluene diisocyanate.
* An unloading checklist form is required to be completed reach time a delivery of bulk chemicals is received.
* Appropriate personal protective equipment is provided to all Schlegel employees involved in the chemical unloading procedure.
These individual elements of our prevention program work together to prevent accidental chemical releases. Schlegel Systems, Inc. and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.
FIVE-YEAR ACCIDENT HISTORY
We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years:
*We have not had any significant releases of toluene diisocyanate (TDI) during the last 5 years
If an incident were to occur we would conduct a formal incident investigation to identify and correct the root cause(s) of the event.
EMERGENCY RESPONSE PROGRAM
We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the Henrietta Fire Department.
We have an in-house emergency response team consisting of approximately 40 employees who have recieved specific training on how to respond to chemcial spills. This training has included scenario is on releases of toluene diisocyanate in a variety of conditions.
* 7 complete Scott Air pack SCBA Units and 19 spare air cylinders
* A completely stocked and mobile spill response cart
* All team members meet monthly to review haz. mat team issues
* All team members are required to train and practice at least quarterly with the Scott Air Pack
* Schlegel Systems, Inc.
contracts with MARCOR to assist Schlegel in the event of a spill for which we needed assistance
PLANNED CHANGES TO IMPROVE SAFETY
The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases:
* All capital projects now require a complete review to be certain all environmental and safety issues are being addressed before
funding will be approved.
* All chemical bulk storage tanks and associated piping are inspected daily, monthly, annually and every 5 years by a certified tank
* Long term project to review and determine the feasibility of utilizing alternatives to toluene diisocyanate that are less toxic or require
that smaller amounts be stored on-site.
Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the wors
t-case accidental release scenario for the following process(es) is less than the distance to the nearest public receptor:
* A complete release of TDI from our on-site chemical storage tank.
Within the past five years, the process(es) has (have) had no accidental release that caused offsite impacts provided in the RMP rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from the process(es), entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMPlan. 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.
For all other covered processes, the undersign
ed also certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the other information submitted in this RMPlan is true, accurate, and complete.
RMP DATA ELEMENTS
The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows:
* Chemical Bulk Storage Tank Inspection Form
* Chemical Bulk Unloading Checklist & Form
* Best Management Practices Plan
* Emergency response program