Schenectady International Inc. - Executive Summary |
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SII is strongly committed to provide a safe and healthy workplace for its employees, and to protect the safety and health of its neighbors. SII's commitment to prevention of accidental releases at its facility is inherent through all phases of manufacturing processes from maintenance, contractor and employee training, to design, installation, and operating procedures. SII's approach to chemical safety conforms to, or exceeds, federal and state regulations, as well as industry standards. In the event of an unforeseeable release, SII is committed to our on-site emergency response personnel and local emergency responding agencies to control and mitigate the effects of such a release. SII is a manufacturer of electrical insulation products, alkylphenols, phenolic resins, and industrial coatings. We currently have one (1) regulated substance at our facility, aqueous formaldehyde solutions, which is used in our phenol-formaldehyde resin batch manufacturing processes. SII's worst case rele ase scenario consisted of a vapor release from a batch reactor containing 18,600 lbs. of formaldehyde with a calculated distance to the toxic endpoint of 0.012 mg/l. The distance to toxic endpoint was determined utilizing the CHARM (Complex Hazardous Air Release Model) dispersion modeling software. Administrative controls, consisting of written operating procedures, prevents more than 18,600 lbs of formaldehyde from being present in the reactor. SII's alternative release scenario consisted of a liquid release of 500 gallons of formaldehyde from a transfer hose during tankwagon unloading operations. This scenario was chosen based on a 5-year historical review of previous accidents at the facility involving formaldehyde. The distance to toxic endpoint of 0.012 mg/l again was calculated utilizing CHARM dispersion modeling software. Active mitigation controls were considered in determining the alternative release scenario. SII requires truck drivers and material handlers to stay with th e tankwagon during unloading operations in the event the transfer operation needs to be terminated immediately. SII has developed a management system to comply with OSHA Process Safety Management (PSM-29CFR Part 1910) regulations and the accidental release prevention requirements established under the Risk Management Program (RMP-40CFR Part 68). SII's prevention program contains all of the Process Safety Management elements which are in place in our facility, such as extensive recordkeeping, process hazards analyses of covered processes, safe operating procedures, extensive employee training programs, mechanical integrity programs, management of change procedures, prestartup reviews, compliance audits, incident investigations, employee participation programs, and contractor safety performance evaluation and training. SII has also incorporated numerous process controls and failsafe systems to significantly reduce the risk of an accidental release from its facility. Examples of these c ontrols and systems include high and low level alarms, metered supply lines, temperature alarms, pressure alarms and relief devices, pH alarms, secondary or backup systems, quench systems, interlocks, automatic shutoffs, check valves, grounding equipment, and purge systems. In addition, much of our process equipment is computer automated. SII had two (2) accidental releases of formaldehyde in the past five years which resulted in on-site injuries and required off-site responses. The first release of an estimated five (5) pounds of formaldehyde occurred in February 1997 and was the result of human error. There were no off-site impacts due to the accidental release. The second release of approx. one (1) pound of formaldehyde occurred in September 1998 and was the result of human error. There were no off-site impacts due to the accidental release. SII has written an emergency response plan for guidance during an accidental release and other site emergencies. This plan is stru ctured to provide for orderly transition from normal to emergency situations, assist in confinement of a fire or chemical release to its' place of origin, aid outside responding agencies in an emergency situation and inform employees and the public of hazards at the facility which may dictate an emergency situation. SII's emergency response plan also includes other aspects of emergency response such as incident command structure, first aid, medical treatment, employee accountability, location and maintenance of response equipment, evacuations, and decontamination procedures. SII is continually improving operations and procedures to improve employee and plant safety. Some of the improvements currently in progress include implementing the Responsible Care program, upgrading existing storage tank facilities, and implementing a plantwide management of change system. |