West Coast Distribution Center - Executive Summary |
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General Executive Summary for Chemical Distribution and Warehousing Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Bayer, Polyurethane Division, are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our activities to prevent accidental releases from the storage and distribution processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release were to occur, emergency response personnel are at hand to control and mitigate the effects of the release. We are also coordinated with the local Fire Department which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass storage and distribution of chemicals that serve the plastics, polyurethane, and dyes and pigments industries. We have two regulated substances presen t at our facility. These substances, 2, 4 toluene diisocyanate and 2, 6 toluene diisocyanate in various mixtures, are used in the manufacturing of flexible polyurethane foams and other elastomers at customer sites. (No manufacturing or processing is done at this distribution center.) These materials are located in two separate processes: a bulk storage process which qualifies as a Program Level 2 process; and warehouse storage for drummed material which qualifies as a Program Level 1 process. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures To evaluate the worst case scenarios, we have used the equations provided by the EPA in the Guidance for Chemical Distributors and the RMP Offsite Consequence Analysis Guidance. One worst case release scenario is submitted for the Program 1 warehouse storage process. The worst case release scenario for this process is the release from a single container o f a mixture containing 98% of 2, 4 toluene diisocyanate and 2% of 2, 6 toluene diisocyanate in a liquid form onto the loading dock area of the warehouse. The release forms a pool which evaporates over a period in excess of 60 minutes. Passive mitigation controls are not taken into account for this scenario. The scenario assumes Class F atmospheric stability and 1.5 m/s windspeed. This release does not extend off-site. One worst case release scenario is submitted for the Program 2 bulk storage process. The worst case release scenario for this process is the release of a mixture containing 80% of 2, 4 toluene diisocyanate and 20% of 2, 6 toluene diisocyanate in liquid form from a railroad car. The release forms a pool which evaporates over a period in excess of 60 minutes. Passive mitigation controls are not taken into account for this scenario. The scenario assumes Class F atmospheric stability and 1.5 m/s windspeed. The release extends a short distance off-site but does not im pact any residential population. No alternative release scenario is submitted for the Program 1 process. Two alternative release scenarios are submitted for the Program 2 process. The alternative release scenarios for the bulk storage process are based on a transfer hose failure which releases a mixture containing 80% 2, 4 toluene diisocyanate and 20% 2, 6 toluene diisocyanate in liquid form while being transferred from a railroad car to a storage tank. Two scenarios are submitted, one for the 2, 4 toluene diisocyanate component and one for the 2, 6 toluene diisocyanate component. Both releases extend for a short distance off-site onto an empty lot. There are no regulated flammable substances above the threshold quantity at this stationary source; thus release scenarios for flammable substances are not submitted. 4. The General Accidental Release Prevention Program Our facility has developed and implemented a prevention program to prevent any accidental releases. This program incorporates the following elements: -- Safety Information -- Hazard Review -- Operating Procedures -- Training -- Maintenance -- Compliance Audits -- Incident Investigation 5. Five-year Accident History Bayer, Polyurethane Division, has had an excellent record of preventing accidental releases over the last 5 years. There have been no accidental release at this facility during this period. 6. Emergency Response Plan Bayer, Polyurethane Division, has a written emergency response plan to deal with accidental releases of hazardous materials. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The seismic assessment of 1992 was reviewed to determine its validity in accordance with the Guidance for California Accidental Release Prevention Program Seismic Assessment, September, 1998. This assessment found no significant structural deterioration or struc tural damage to the facility. No recommendations were made. 8. Certification Statement 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. Name: Signature: Title: Date signed: |