Texas Fibers - Executive Summary |
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Executive Summary 1.0 Accidental Release Prevention and Emergency Response Policies At Texas Fibers, Brenham, Tx. , we are committed to operating and maintaining all of our processes (especially those using hazardous substances) 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 offsite consequences from accidental chemical releases An overview of our accidental release prevention programs A five-year accident history for accidental re leases of chemicals regulated by EPA's RMP rule An overview of our emergency 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 2.0 Stationary Source and Regulated Substances Our facility produces flexible polyurethane foam using a variety of chemicals and processing operations. The facility is housed in an approximately 125,000 sq. ft. building located in an industrial area. The process area is divided into two areas; one being the process building, which houses the tank farm, which is diked, and the process area located in the upper half of the process building. In our processes, we use the following chemicals that EPA has identif ied as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics: See Appendix E, MSDS for Toluene Diisocyanate. Flammables None. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. 3.0 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 See Appendix A, for Worst-case Release Scenario. The scenario is a rail car failure dumping the entire cont ents of the car. This scenario has the possibility of impacting the small residential population around the facility. Diagrams, and modeling information used to develop the Worst-case scenario is located in our written program.. Alternative Release Scenario(s) - Regulated Toxic Chemicals For an alternative release scenario we used a line break. The modeling scenario indicated that there are no public or environmental receptors. The modeling information is located in appendix a of the written program. Worst-case Release Scenario(s) - Regulated Flammable Chemicals None. Alternative Release Scenario(s) - Regulated Flammable Chemicals None. 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. 4.0 General Accidental Release Prevention Program and Chemical Specific Prevention Steps We ta ke a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: Process hazard assessment Process hazard review Operating procedures Training Mechanical integrity Compliance audits Incident investigation Employee participation Hot work permit Contractors The key to preventing accidental chemical releases are the Standard Operating Procedures that are in Appendix D. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company 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. 5.0 Five-Year Accident History We keep records for all significant accidental chemical re leases 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: There have been no accidental releases of TDI in the past 5 years. 6.0 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 community emergency response plan. 7.0 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: 1. Additional two-w ay radios to improve communications during operations. 2, Fixed monitors. 3. High level alarms. 8.0 Certifications Based on the criteria in 40 CFR 68.10, our Risk Management Program is written to comply with Program level two. The distance to the specified endpoint for the worst-case accidental release scenario for the covered process may impact the small residential population surrounding the facility. Within the past five years, the process has had no accidental releases that caused offsite impacts provided in the RMP rule (40 CFR 68.10(b)(1)). We have taken voluntary measures to improve our operations to minimize potential releases of covered materials in order to protect both our employees and the public. In the event of fire, explosion, or a release of a regulated substance from the process, entry within the distance to the specified endpoint 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. Signature_________________________________________ Title_____________________________________________ Date_____________________________________________ 9.0 RMP Data Elements The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. The information is categorized as follows: - Registration - Offsite consequence analysis - Five-year accident history - Program 2 prevention program - Emergency response program |