Marchem Technologies UPDATE TDI - Executive Summary |
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EXECUTIVE SUMMARY The Risk Management Plan (RMP) has been prepared for Marchem Technologies, LLC (Marchem) facilities at 20851 South Santa Fe Avenue, Long Beach, California in accordance with the requirements of the California Code of Regulation (CCR) Title 19, Division 2, Chapter 4.5 (California Accidental Release and Prevention Program [CalARP]). This is an update of the original RMP submittal on June 7, 1999. Marchem manufactures surface-active agents (surfactants) and has an SIC Code of 2843. Four state regulated acutely hazardous materials are used, handled, or stored for manufacturing processes above the State Threshold Quantity (STQ): dimethyl sulfate, epichlorohydrin, ethylene oxide and propylene oxide. Processes handling these substances were determined to be eligible for Program 3 requirements. In addition, Marchem now plans to use, handle and store a fifth state regulated acutely hazardous material for manufacturing processes above the STQ: Toluene Diisocyanate. Th is substance was determined to be eligible for Program 2 requirements. A Hazard and Operability (HAZOP) Team was established by Marchem to conduct HAZOP studies and Process Hazard Analyses (PHAs) during the first calendar quarter of 1999. During this time period, all previously conducted HAZOP studies and PHAs were reviewed and updated to incorporate recent process changes and modifications at Marchem's facilities. The HAZOP Team consisted of the plant manager, plant operation manager, process operators, facility maintenance personnel, laboratory staff and outside technical consulting professionals from PES Environmental, Inc. The guideword approach was used in conducting HAZOP studies and PHAs to identify hazards. Identified risks were assessed for likelihood and severity. Using the risk matrix from Appendix M, Region I LEPC, CalARP Implementation Guidance Document, each risk was evaluated as being acceptable, acceptable with controls, undesirable, or unacceptable. Based on eac h evaluation, remedy action issues were identified, discussed, and recommended for implementation. A similar HAZOP and PHA was conducted for TDI. The TDI team consisted of the EHS manager, Production manager, Operators, Process engineer and Maintenance mechanics. The HAZOP Team also conducted an External Events Analysis. The following external events were determined to have a reasonable probability of occurrence and were evaluated: aircraft impact, external flooding, extreme winds, hail, high summer temperature, lightning, missile impact, sabotage, seismic activity, and transportation accidents. Missile impacts that may result from extreme winds, high summer temperature, lightning and seismic activity were found to present the greatest risk with undesirable or unacceptable consequences. Details of the analyses and risk evaluation along with resulting recommended actions are provided. Off-Site Consequence Analyses were conducted for one worst case and five alternate release sce narios to evaluate human health and environmental impacts associated with an accidental release. The first scenario, worst case scenario as defined by Section 112 r (7) of 40 CFR Part 68 for a toxic gas, is the release of the maximum quantity of ethylene oxide in storage over a period of ten minutes. This was chosen as the tank car release, since the storage tank is passively mitigated by location as an underground storage tank. Based on air dispersion modeling using average meteorological conditions, four alternative accidental release scenarios were identified during the HAZOP studies, PHAs and/or external event analyses. These release scenarios involved: a) the rupture of the ethylene oxide vapor return line during a seismic event while unloading a tank car, actively mitigated by detection of the spill and shutdown of the system; b) the rupture or failure of the propylene oxide loading line during a seismic event, c) the rupture of the DMS conveyance line to the process area, a ctively mitigated by operator in charge of process whenever system is running, d) the spill of epichlorohydrin in the drum storage area as a result of a forklift accident and e) the failure of a suction flex line in the TDI pump. These release scenarios were determined by the HAZOP Team to be likely and credible, being associated with either the compounded failure of administrative process controls, mechanical integrity, safety systems, or a serious external event. A detailed description of all incident categories that could have involved the four acutely hazardous materials processed at the Marchem chemical manufacturing facility during the past five years is provided in Section 3.0. During this period there have been no reportable incidents at Marchem in the following categories: personnel injury or illness, environmental release, and community exposure beyond Marchem's property boundary. Marchem has prepared, maintains, and conducts periodic training of its Emergency Action Pl an. This plan describes the procedures by which an emergency response is handled by the management team and operators at Marchem. All employees at Marchem, including on-site contractors, are periodically trained on the Emergency Action Plan. A detailed discussion of the plan is provided at Section 5.0. Previous process safety related recommendations have been reviewed for appropriate implementation at the Marchem facility. PHA recommendations for TDI are currently under review for implementation. |