McWhorter Technologies, Inc. - Forest Park, GA - Executive Summary |
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McWhorter Technologies, Inc. (MWT) owns and operates an alkyd and polyester resin manufacturing facility in Forest Park, Georgia. MWT has determined that the Toluene diisocyanate (TDI) (CAS No. 26471-62-5) handling and storage process at the facility is subject to the Chemical Accident Prevention Provisions, referred to herein as the Risk Management Program (RMP) rule. The RMP rule requires each affected facility to prepare an RMP report for submittal to the U.S. Environmental Protection Agency's RMP Reporting Center. Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental release scenario for the TDI process is less than the distance to the nearest public receptor and in fact stays within the MWT fenceline. Thus MWT is a Program 1 source per the RMP rule. TDI is the only regulated substance used in amounts greater than the threshold quantity at the Forest Park facility. TDI is regulated as a toxic substance under the RMP rule. The threshold quantity for TDI in a single process is 10,000 pounds (lbs.). TDI is currently stored in an 8,460-gallon (gal) storage tank (i.e., maximum physical capacity of the tank is 86,123 lbs. of TDI). The TDI storage tank (designated R-19) is located on the southeast side of the raw material tank farm and is surrounded by a dike. Pressure relief valves are connected to one 55-gal carbon drum (located inside the TDI tank's dike) which captures excess TDI vapors. The tank emergency vent is connected to a 55-gal drum of Tergitol, used to neutralize any TDI that might escape from the tank in the event the emergency relief opens. The tank is protected by a water deluge system and liquid level alarm, which activates a shut-off valve to stop the flow of TDI into the tank. In addition, the maximum active volume of TDI present in the storage tank at any one time is limited by administrative controls designed to manage TDI deliveries and purchases. Every morning a tank inventory list is automatically generated (based on level gauges located in facility tanks). An agent from the Accounting Office reviews the tank inventory list and places an order only when the list indicates that the R-19 tank has available space to accommodate a TDI delivery. As an added precaution, the dike surrounding the TDI tank can contain 110% of the tank's capacity. By following these procedures, the maximum volume of TDI in the tank will always be less than the dike containment volume. The Forest Park facility has a written emergency response plan, and appropriate mechanisms are in place to notify the local fire department in the event of a TDI release. The facility is also subject to the strict Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) rule, which is similar to a Program 3 RMP. OSHA PSM requirements include the following elements: * Process Safety Information * Process Hazard Analysis * Operating Procedures * Training * Mechanical I ntegrity * Management of Change * Pre-Startup Review * Compliance Audits * Incident Investigation * Employee Participation * Hot Work Permit * Contractors Since the OSHA PSM rule is also more stringent than the RMP Program 1 requirements (as applicable to TDI in this submittal), MWT is working responsibly to maintain a safe environment for its workers and the neighboring community. |