Crest Foam Industries Incorporated - Executive Summary |
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Introduction Crest Foam Industries Incorporated uses Toluene Diisocyanate (TDI) to manufacture flexible polyurethane foam products at its plant in Moonachie, New Jersey. The TDI is received in 40,000 pound truckload quantities and off loaded into storage containers. The total quantity of TDI at the plant never exceeds 110,000 pounds. Crest Foam Industries Incorporated initially developed a Risk Management Program (RMP) for the facility in order to comply with the requirements of New Jersey's Toxic Catastrophe Prevention Act (TCPA). The RMP being submitted is derived from that original plan. Crest Foam Industries Incorporated has developed a thorough program for the safe handling of TDI at their plant. This program has been successfully operating since September 1988. The program is audited annually by the NJ Department of Environmental Protection. The company has not had a reportable accident in over five years. Included at the end of the summary are descriptions and results o f the worst case & alternative release scenarios. For both cases, the estimated radius to toxic endpoint is 0.1 miles with an impact on the surrounding population of approximately 84 people. The estimated radius to toxic endpoint was calculated using the EPA's RMP*Comp program, while the effects to the offsite population were calculated using the EPA's Landview program, which utilized census data for Bergen County, NJ. This executive summary describes the elements of the Crest Foam Industries Incorporated RMP program which include: ? Standard Operating Procedures ? Safety Review ? Preventive Maintenance ? Operator Training ? Accident Investigation ? Risk Assessment ? Emergency Response ? Risk Management Program Audits Standard Operating Procedures Standard Operating Procedures include the following elements: process flow sheets; procedures for normal operations; description of abnormal conditions and appropriate corrective actions; description of emergency conditions and appropr iate corrective actions; pre-startup, startup, and shutdown procedures; description of safety devices; safety procedures; sampling procedures; material data sheets; manpower requirements; and development of an index to procedures and information. The Standard Operating Procedures are continually updated to reflect any changes modifications to the system. Safety Review The Safety Review involves comparing facility design, equipment, and operations with the current state-of-the-art. The safety review also requires that the plant be visually inspected to determine if safety devices are functioning properly, if actual operating conditions are within design limits, and if the actual conditions reflect Standard Operation Procedures. The findings and any deficiencies are then documented in a written report. A number of documents must be prepared to facilitate the safety review. These documents include: process description and process chemistry, process flow sheets, piping and instrum ent diagrams, facility location maps, site plans and equipment layout, electrical one-line diagrams, electrical area classification drawing, specifications far safety release devices, specifications for materials of construction, EHS inventories, and a listing of external forces and events (such as floods. power outages, etc.) that could influence safe operations. The documents required to support a safety review have been assembled from existing drawings. The company's plant engineer performs the formal safety review on an annual basis. Preventive Maintenance The preventative Maintenance Program consists of procedures for maintaining equipment safety, establishing the frequency and scheduling of maintenance work, and documenting the process. The Preventive Maintenance Program includes: a listing of TDI-related equipment; procedures for controlling equipment modifications; a schedule for equipment inspections; schedule and procedures for testing safety devices; schedule and proced ures for check of safety instruments; procedures for commissioning/decommissioning equipment; schedule and content of preventive maintenance training; procedures for maintenance by outside contractors; permits and checklists for TDI-related equipment entries, lockouts, and welding; central filing system for tracking inspections, breakdowns and repairs suitable for data retrieval and analysis; and tables comparing the actual to planned program of preventive maintenance, inspection, and tests. The execution of the plan is the responsibility of the Foam Line manager and the Plant Manager. Operator Training The Operator Training Program includes: written job descriptions; procedures to qualify operators; frequency and duration of programs; training manuals and guidelines for instructors; documents to track training program for each employee; and a table summarizing operator training performed during the year. A combination written and video cassette Operator Training Program has been developed and is in use along with on-the-job training for all operators. Accident Investigation The Accident Investigation Procedure includes: written procedures for TDI accident investigations, an accident report form, a form to track the status of corrective actions, an employee error form, and a year-end summary form. The program includes the review of past risk reduction measures and the training of the TDI operators in the use of the accident report forms. The company's Lab/Chemist is responsible for managing this program. Risk Assessment Crest Foam Industries Incorporated completes a hazard analysis at least once every 5 years for the TDI system. The hazard analysis involves reviewing equipment failure records and accident reports to identify possible causes of accidental releases of TDI using a "what if' analysis or another accepted procedure. The accident scenarios are then classified as major or minor, depending on the amount of TDI that could be released. A poss ible major release is defined as one in which the quantity of TDI released would be five times the acute toxicity concentration. Risk reduction measures are then developed. For major releases, the risk reduction measures are evaluated by means of a risk assessment. This involves estimating the extent, travel speed and concentration of the release using a dispersion analysis, if applicable, and then estimating the consequences on surrounding populations. For minor releases, the risk reduction measures are recommended based on an estimate of the reduction in probability or quantity of the release. The result of the hazard analysis is then summarized in a written report. Emergency Response A written emergency Response Plan has been prepared and includes the following elements: a description of the TDI operations and their location; a list of emergency response equipment and their location; the name of the site emergency coordinator and alternates; organization charts identifying in -house emergency response teams, emergency response support from contract or mutual aid groups, and government responders to the emergency; a description of the site's emergency notification system; a description of on-site monitoring equipment for TDI; procedures to mitigate and control effects of a spill; procedures for first aid and medical treatment at off-site facilities; an evacuation plan for site personnel; and a plan for building re-entry. The program also includes training of the emergency response team, conducting evacuation drills, and evaluating personnel performance during evacuation drills. The plan has been transmitted to the local fire department by the responsible manager and is incorporated into the community's response plan. Risk Management Program Audits An audit of the plant's Risk Management Program is completed annually and a written report is prepared and reviewed by the responsible manager. Written procedures for conducting the audit have been developed and are implemented by our safety coordinator. Worst Case Scenario The worst case scenario for the RMP is the largest possible spill of TDI which could reasonably occur at Crest Foam Industries Incorporated. This spill would be the rupture of our TDI storage tank #4. The amount of material that would be discharged is 73,515 pounds. Taken into consideration in the formulation of this scenario is the fact that the tank would be discharged into a diked area within the confinements of the building. The RMP*Comp simulation results are enclosed below. RMP*Comp Results of Consequence Analysis Chemical: Toluene diisocyanate (unspecified isomer) CAS #: 26471-62-5 Category: Toxic Liquid Scenario: Worst-case Quantity Released: 73515 pounds Liquid Temperature: 70 F Mitigation Measures: Diked area: 600 square feet Dike height: 2 feet Release into building with floor area of 62000 square feet Release Rate to Outside Air: .000504 pounds per minute Evaporation Time: 146000000 minutes Topograp hy: Urban surroundings (many obstacles in the immediate area) Toxic Endpoint: 0.0070 mg/L; basis: EHS-LOC equivalent (Not an EHS; LOC-equivalent value is based on IDLH for toluene 2,4-diisocyanate.) Estimated Distance to Toxic Endpoint: 0.1 miles (0.2 kilometers) --------Assumptions About This Scenario--------- Wind Speed: 1.5 meters/second (3.4 miles/hour) Stability Class: F Air Temperature: 77 degrees F (25 degrees C) ------------------------------------------------ RMP*Comp Results of Consequence Analysis Chemical: Toluene diisocyanate (unspecified isomer) CAS #: 26471-62-5 Category: Toxic Liquid Scenario: Alternative Quantity Released: 40000 pounds Release Duration: 1.0 minutes Release Rate: 40000 pounds per min Liquid Temperature: 77 F Mitigation Measures: NONE Release Rate to Outside Air: .230 pounds per minute Evaporation Time: 174000 min Topography: Urban surroundings (many obstacles in the immediate area) Toxic Endpoint: 0.0070 mg/L; basis: EHS-LOC equivalent (Not an EHS; LOC-equivalent value is based on IDLH for toluene 2,4-diisocyanate.) Estimated Distance to Toxic Endpoint: 0.1 miles (0.2 kilometers) --------Assumptions About This Scenario--------- Wind Speed: 3 meters/second (6.7 miles/hour) Stability Class: D Air Temperature: 77 degrees F (25 degrees C) ------------------------------------------------ |