Polaris-Oseola - Executive Summary |
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In this facility, we produce recreational vehicles. We use 2 materials considered hazardous by the Environmental Protection Agency (EPA): liquified propane for use as an alternate heating fuel and toluene diisocyanate (ISO) which is used to make the seat cushions for our recreational vehicles. The same properties that make ISO valuable in making rv seats also makes it important to observe certain safety precautions in handling this material to prevent unnecessary human exposure. Our policies, process and equipment design/operation and safe work practices are all meant to provide protection for our co-workers, the community and the environment. It is our policy, as a minimum, to conform to all applicable federal, state and local requirements. In the case of propane, we also conform to the National Fire Protection Association's requirements for LP-Gas STorage (NFPA-58) and our system has been approved by Factory Mutual. For ISO, we follow practices recommended by the supplier, BAS F, and the Polyurethane Division of the Society of the Plastics Industry, Inc. We have gone further to assure the safe operation of our regulated processes by adopting an accident prevention plan. A number of equipment and procedural changes have been made to the propane and ISO systems resulting from a comprehensive hazards analysis conducted in March, 1999. We have assured that all drivers and material unloading personnel have been trained and certified in safe work practices. The worst-case scenario for failure of the propane storage tank is a vapor-cloud explosion involving less than 100,000 pounds of propane, with an environmental impact zone of 0.37 miles and potentially affecting approximately 300 people offsite. A more likely scenario for propane is release through a hole or punctured pipe, resulting in a vapor cloud fire with an impact zone of less than 0.1 miles. The scenarios for ISO are flawed using RMP*Comp, provided by the EPA and maybe recalculated using an EPA-a pproved model that more realistically represents the chemical and historical weather conditions. The worst-case scenario using RMP*Comp involves release of 55,900 lbs of ISO into our building, resulting in evaporation and release to the outside air over nearly 872,000 hours. The calculated end point is 0.1 miles, or 528 feet, potentially affecting 128 people. The alternate ISO release scenario, again using RMP*Comp, involves a faulty hose connection to the delivery truck, resulting in 101 lbs. of material contained in a spill pan. The liquid would evaporate to the outside air, this time over a 8,000 hour time-period, to the same end point of 0.1 miles. We have had small, in-plant ISO releases, one resulting in a worker injury. A thorough investigation was made and a material failure problem identified and corrected. We have never had an incident involving propane or ISO that caused public deaths, injuries, environmental damage or shelter-in-place. In the unlikely event that an emergency were to occur, the facility response plan would be put into effect. This plan is coordinated with our contracted hazardous waste responder- Waste Recovery Resource (WRR-Resco), the Osceola Police and Fire Departments, the Polk County Sheriff, the Osceola Medical Center, the Municipal Ambulance Service, and the Polk County Office of Emergency Management. |