TAM Ceramics, Inc. - Executive Summary |
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GENERAL: In accordance with 40 CFR Part 68.155, this executive summary includes a brief description of the following program elements: The accidental release prevention and emergency response policies at the TAM facility; The TAM facility and regulated substances handled; The worst case release scenario; The general accidental release prevention program and chemical specific steps; The five year accident history; The emergency response program; and Planned changes to improve safety. ACCIDENTAL RELEASE PREVENTION & EMERGENCY RESPONSE POLICIES: The TAM facility maintains this RMP in accordance with Section 112(r) of the CAA in addition to a Spill Prevention Report in accordance with New York State's Chemical Bulk Storage regulations (6 NYCRR Parts 595-599). Both of these documents include accidental release prevention provisions for the TiCl4 process at the facility. Additionally, the TAM facility maintains a Hazardous Waste Contingency Plan which includes p rovisions for emergency response in the event of an accidental release of TiCl4. TAM FACILITY & REGULATED SUBSTANCES: The TAM facility stores up to 5,000 gallons (72,400 pounds) of liquid TiCl4 in one 5,000 gallon aboveground storage tank, which exceeds the threshold quantity of 2,500 pounds specified in the 112(r) rule. The TiCl4 is used to provide titanium for the ceramic manufacturing process. WORST CASE RELEASE SCENARIO: The worst case release scenario consists of an instantaneous release of the entire maximum contents (up to 72,400 pounds) of the TiCl4 tank into the existing secondary containment area. The actual rate of release of TiCl4 to air is based on the volatization rate of the liquid TiCl4 pool in the secondary containment area. Therefore, air dispersion modeling was performed as part of this worst case scenario to evaluate the distance to the TiCl4 toxic endpoint. The air dispersion modeling results indicated that the distance to the TiCl4 toxic endpoint is appr oximately 39 feet. As shown on the facility layout drawing in Figure 2, the TiCl4 tank is located well within the fenceline of the facility with the nearest fencline being appproximately 300 feet from the TiCl4 storage tank. There are no public or environmental receptors located within a 39 foot radius of the TiCl4 storage tank. The air dispersion model also indicated that elevated concentrations of Hydrogen Chloride (HCl) gas would be formed during a worst case release scenario, as TiCl4 is highly reactive with the moisture in the air. Since HCl gas is not stored above a threshold quantity, it was not considered as part of this RMP. However, TAM currently has plans to install a system to alleviate this situation. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM: The TiCl4 process at the TAM facility is in compliance with Section 112(r) of the CAA and the New York State CBS regulations. Chemical-specific prevention steps are included in the facility's CBS Spill Prevention Report. FIVE YEAR ACCIDENT HISTORY: The TAM facility has not experienced any accidental release of TiCl4 in the past five years (March 1994-May 1999). EMERGENCY RESPONSE PROGRAM: The TAM facility maintains a Hazardous Waste Contingency Plan which includes emergency response procedures to be followed in the event of an accidental release of TiCl4. The Plan has been coordinated with local emergency response agencies, including the State Emergency Response Commission. The Plan also includes provisions for public notification in the event of a release. PLANNED CHANGES TO IMPROVE SAFETY: The TAM facility currently has plans to install a foam suppression system at the TiCl4 storage tank location. In the event of a release of TiCl4 to the secondary containment area, the foam suppression system will activate and release a layer of foam over the liquid TiCl4. The foam will serve as a vapor barrier and will prevent the release of TiCl4 and its reactant products to the atmosphere. |