Tremco Incorporated - Mameco Division - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
At Tremco Incorporated - Mameco Division, 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 releases of chemicals regulated by EPA's RMP rule
* An overview of our emergency
* 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 caulks, sealants and weatherproofing materials using a variety of chemicals and processing operations. Most of our products are polyurethanes. In our processes, we use toluene diisocyanate (TDI) which EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release. We store TDI in a 6,000 gallon storage tank which is located inside one of our buildings. We pump the TDI to various kettles where most of it is reacted with polyols and other chemicals leaving only residual levels of TDI from that point on.
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.
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
EPA's RMP rule requires that we provide information about the worst-case release scenario for our facility. The following is a brief summary of this scenario, including information about the key administrative controls and mitigation measures to limit the exposure distances for this worst-case scenario:
The worst-case release scenario selected is the rupturing of the TDI storage tank leading to the instantaneous release of 61,000 pounds (6,000 gallons) of liquid TDI to a 1,444 square foot containment area inside a building. The TDI in the storage tank is maintained typically at 110F. Since the maximum temperature could possibly be as high as 120F, this higher temperature was used. The meteorological conditions used in the
dispersion analysis were chosen according to RMP rule requirements and incorporated data maintained by the National Climatic Data Center. The ALOHA model developed by the U.S. EPA and the National Oceanic and Atmospheric Association for predicting the dispersion of toxic material releases in air was used.
The ALOHA model estimates an evaporation rate from the pool of 0.028 pounds per minute. Because the release is indoors, the release rate to the environment is approximately one-tenth of the release inside the building. Using the lower release rate of 0.0028 pounds per minute, the ALOHA model estimates the downwind distance to the toxic endpoint (0.98 ppm or 0.007 mg/liter) to be 0.019 miles which is 100 feet. This distance is less than that to the nearest public receptor which is more than 125 feet away.
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency case
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address the key features of successful prevention programs. 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.
FIVE-YEAR ACCIDENT HISTORY
We have had no significant accidental chemical releases involving materials covered under EPA's RMP rule during the past five years:
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 the workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan.
PLANNED CHANGES TO IMPROVE SAFETY
As part of our philosophy of continuous improvement, we are constantly seeking enhancements to implement at the facility to help prevent and/or better respond to accidental chemical releases.