The Truesdale Company - Executive Summary
General Executive Summary for a Chemical, Distributor Facility |
1. Accidental Release Prevention and Emergency Response Policies
We at The Truesdale Company are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances.
2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activities encompass Chemical distribution. We have 1 regulated substance present at our facility. This substances is Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-]. Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-] is used for Distribution/Sales only.
The maximum inventor
y of Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-] at our facility is 94000.00 lb..
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario
To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 2 toxic substances as a class involves a catastrophic release from semi bulk tanks. In this scenario 2,200 lb. of Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-] is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 360,000 minutes if not neutralized. The released quantity has been limited to ___2.3%
of the maximum capacity of the source by a system of administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.10 miles is obtained corresponding to a toxic endpoint of 0.0070 mg/L.
The alternative release scenario for Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-] involves a release from TDI. The scenario involves the release of 550 lb. of TDI. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 210,000 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0070 mg/L of Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-] is 0.1 miles.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements
set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
The Truesdale Company maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is Onsite review. The studies are undertaken by a team of qualified personnel with expertise in process operations and are revalidated at a regular interval of _5 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 09/22/1
For the purposes of safely conducting activities within our covered processes, The Truesdale Company maintains written operating procedures in our Plant Manual. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.
The Truesdale Company has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every _2_ years and more frequently as needed.
The Truesdale Company carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among ot
hers; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at The Truesdale Company to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 05/05/1999. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.
Pre-start up safety reviews related to new processes and to modifications in established processes
are conducted as a regular practice at The Truesdale Company. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
The Truesdale Company conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 11/20/1996. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
The Truesdale Company promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained fo
r a minimum of 5 years.
The Truesdale Company truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.
On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. The Truesdale Company has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substa
5. Five-year Accident History
The Truesdale Company has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period.
6. Emergency Response Plan
The Truesdale Company carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.
Boston LEPC is the Local Emergency Planning Committee (LEPC) with which our emergen
cy plan has been coordinated and verified.
7. Planned Changes to Improve Safety
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Some of the major steps we want to take to improve safety at our facility include:
7 Advanced Forklift training.
7 Frequent safety meetings.
7 New exhaust system.
7 Wide aisles in warehouse through inventory management.
7 Replace Aluminum dock boards with steel boards.
7 Install new fire exit doors.
These changes have been implemented.