Proviron America, Inc. - Executive Summary |
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The Proviron America, Inc. (PA) facility's accidental release prevention policy involves an approach that integrates technologies, procedures, and management practices. All applicable procedures of the U.S. Environmental Protection Agency (EPA) Prevention Program are adhered to. The PA emergency response policy involves the preparation of response plans which are tailored to the facility and to the emergency response services available in the community. PA has been designed to toll manaufacture commodity and specialty chemicals. These chemicals include polyurethane intermediates and catalysts, surfactants, polymers and prepolymers. These chemicals supply a variety of customers in the United States and the world. The facility is located on Industrial Park Road off WV South State Route 2, ~700 feet from the Ohio River. The facility includes an office area, a laboratory and a production hall. The amount of Ethylenediamine (EDA) handled at one time is a truck load (45,00 lbs.) The facilit y is normally operated by 8 full-time employees. There is one shift per day of 8 hours, 5 days a week. The off-site consequence analysis includes consideration of two EDA release scenarios, identified as "worst case release" and "alternate scenario". The first scenario is defined by the EPA, which states that the owner or operator shall assume that the maximum quantity in the largest vessel is spilled instantaneously and released as a gas over 10 minutes due to an unspecified failure. The alternative scenario is explained as a more likely to occur (day to day) scenario. Atmospheric dispersion modeling and calculations were used to determine the distance traveled by the EDA released before it's concentration decreases to the "toxic endpoint" selected by the EPA of 0.49 mg/L (0.49 ppm), which is the Extremely Hazardous Substance - Level of Concern (Immediately Dangerous to Life and Health) or EHS-LOC (IDLH). This is defined by the American Conference of Government Industrial Hygienist s (ACGIH). The population within a circle with the radius corresponding to the toxic endpoint distance has to be defined to estimate the population potentially affected. The worst-case release scenario at the PA facility involves a failure in the system that releases the entire amount material in the truck (45,000 lbs.). The conditions are pre-defined by the EPA, namely the instantaneous release of the entire amount as a liquid, determine the amount of vapors released from the liquid pool, use the EHS-LOC (IDLH) as the toxic endpoint, and determination of the population residing within a full circle with a radius corresponding to the toxic endpoint distance. The EPA set these conditions to facilitate the performance of the off-site consequence anaysis. EPA-mandated meteorological conditions, namely Stability F, wind speed of 1.5 m/sec., highest daily maximum temperature (250C = 770F), and average humidity (50%) were used. When calculationsand atmospheric despersion modeling for the worst case scenario was performed using the EPA assumptions, a distance to the toxic endpoint of 5.3 miles and an estimate of residential population potentially affected of 27,660 was obtained. This accounts for all the residents within the circle in all directions. The alternative release scenario involves the rupture or clean break of the flexible 2 inch chemical hose connection between the tank truck and the drumming station. The material ia at an elevated temperature of 950F (350C). The trailer is pressurized with nitrogen to 20 psi. The amount of EDA released into the liquid pool is 5,781 lbs., at an average vapor release rate over 1 hour (the duration of the release) of 97.86 lbs./min. The toxic endpoint distance was obtained. The EPA default meteorological conditions were used; Stability Class D, wind speed 3.0 m/sec., averageair temperature of 770F (350C), and 50% average humidity. The estimated distance traveled to the toxic endpoint is 0.43 miles. Mitigation to consider is the presence of PA operators and the truck drivers. The truck drivers are trianed in the handeling of the hazards of the material and have the appropriate personnel protective equipment (PPE) to respond to an incident. The PA operators have detailed operating instructions for the drumming process of EDA and continually monitor the process through completion to detect any incidents or failures in the system. The general PA accidental release prevention program is based on the following key elements: a. Training of the operators. b. Preventative Maintenance Program. c. Use of proper process and safety equipmet. d. Use of accurate and effective operating procedures, written with the participation of the operators. e. Performance of a Pre-Startup Safety Review of equipment and procedures before a process is accepted into production. f. Monthly inspection program. Chemical-specific prevention steps include availability of air-purifying respirators, worn by the oper ators during connection/disconnection and the drumming of EDA and awareness of the hazaeds and toxic properties of EDA. No accidental releases of EDA have occured at this facility in the past 5 years. The facility has an emergency response program, which has been coordinated (reviewed) by the City of Sistersville Fire Department, which is a member of the Local Emergency Response Planning Committee (LEPC). This program includes an emergency response decision process and a notification plan. Emergency response drills evaluations will be conducted on a yearly basis, emergency operations and response proceduresare also reviewed at that time. The local fire department (Sistersville) visits the facility yearly to familiarize themselves with the plant and the hazards. |