Adco Chemical Company - Executive Summary

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Adco Chemical Company's management is committed to operating a safe manufacturing facility.  The employees receive periodic refresher training and participate in annual emergency response exercises. 
Adco Chemical Company manufactures synthetic resin at the facility.  It uses Toluene diisocyanate (unspecified isomer - CAS # 26471-62-5) for manufacturing urethanes.  Toluene diisocyanate (TDI) is a regulated substance under the "Accidental Release Prevention" regulation, under the Clean Air Act, Section 112 (r) (7).  Adco procures, stores and handles TDI only in 55 gallon drums to minimize any potential release of TDI. 
The maximum quantity of TDI stored at the site is 60,000 pounds.  However, the typical quantity of TDI stored at the facility is at least half the maximum quantity.  The maximum quantity of TDI used in a production batch is 6,000 pounds, which is below the threshold quantity of 10,000 pounds for TDI under the Accidental Release Prevention regulation.   
Therefore, storage is the only process covered under the regulation. 
The worst-case release scenario of the spill of two drums of TDI would not have any off-site impact, as the distance to toxic endpoint estimated using the EPA's Offsite Consequence Analysis (OCA) guidance is approximately 97 feet.  Similarly, the alternate release scenario of the spill of one drum of TDI would have no off-site impact. The release rate for these scenarios is apprximately 0.003 lb/min. However, the value reported is .2, since the software does not allow to enter value less than .2. 
Adco developed a Risk Management Program (RMP) for TDI under the New Jersey Toxic Catastrophe Prevention Act (NJ-TCPA) regulation.  The program was approved by the NJDEP on September 5, 1988.  NJDEP has inspected the facility annually to verify compliance with the program.  Some of the provisions at the facility to minimize potential release of TDI include: 
1. The facility does not handle TDI in bulk.  TDI is only handled  
in 55-gallon drums. 
2. TDI is stored in a separate room in the warehouse.  The room is separated from the flammable material in the warehouse with a fire door and fire wall. 
3. The TDI room is provided with a sprinkler system. 
4. The TDI room is equipped with a TDI monitor with alarm to detect any spills of TDI in the room. 
There has been one TDI related accident in the last five years.  There was minor injury to Adco employee but no offsite impact from this accident. The quanity of TDI involved in the accident was less than .1 lb (the software does not allow entry of value less than 1 lb).  Since the accident occured inside a building, weather   parameters were not recorded.   
Adco Chemical Company has a Combined Emergency Response Plan (Plant Operation #59) to respond to any emergency at the facility.  A copy of the plan has been distributed to all local emergency responders and plant emergency response members.  All new employees are provided with initial orientation training.  
Annual refresher training is provided to all employees.  In addition, the emergency response team participates in annual emergency response exercises. 
The facility has been implementing a number of items since entering into the NJ-TCPA program for TDI in 1988.  These items have included procurement of TDI monitors, minimizing TDI inventory, having a separate room for TDI storage with fire doors and walls, sprinkler system and TDI monitor for TDI storage room, installation of alarms for the processes using TDI, training for employess for safe operation and emergency response.  We believe as a result of these items, TDI operations at the facility are  safe.
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