Cardolite Corporation - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
At Cardolite Corporation, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner.  We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment.  This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: 
 
*  A description of our facility and use of substances regulated by EPA's RMP regulation 
*  A summary of results from our assessment of the potential offsite consequences from accidental chemical releases 
*  An overview of our accidental release prevention programs 
*  A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 
*  An overview of our emergency response program 
 
*  An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment 
*  The certifications that EPA's RMP rule requires us to provide 
*  The detailed information (called data elements) about our risk management program 
 
STATIONARY SOURCE AND REGULATED SUBSTANCES 
 
Our facility produces products used by the friction materials, and coatings industries using a variety of chemicals and processing operations.  In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: 
 
Toxics: 
 
1. epichlorohydrin 
2. ethylenediamine 
 
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. 
 
KEY OFFSITE CONSEQ 
UENCE ANALYSIS SCENARIOS 
 
EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility.  The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: 
 
Worst-case Release Scenario(s) - Regulated Toxic Chemicals 
 
The worst case scenario is the complete rupture of the completely full epichlorohydrin tank.  The tank contents would be released immediately into the secondary containment diked area.  Using the EPA OCA methodology, the material would evaporate at a rate of 22.7 lb./min., and would create an area with concentrations above the  toxic threshold out to a distance of 0.6 miles (3190 ft.).  The list of potentially impacted receptors is: 
1. AFA Pallet 
2. NJ Transit bus repair facility 
3. Sun Chemical facility 
4. Reichold Chemical facility 
5. General Chemical facility 
6. Darl 
ing Delaware facility 
7. Passaic Valley Sewage Authority 
8. Newark Bay Cogeneration facility   
9. Miles Inc. facility 
10. Louis Dreyfus Energy 
11. Texaco sales Terminal 
12. Amerada Hess 
 
Administration controls include inventory control, training, constant surveillance, preventive maintenance, and Process Safety Management measures.  Mitigation measures include the secondary containment dike, emergency response plan, training in spill control, and contacting of outside agencies and closest neighbors.      
 
Alternative Release Scenario(s) - Regulated Toxic Chemicals 
 
1.  For epichlorohydrin, an alternate scenario involves a failure of the unloading line while a tank wagon of the material is being unloaded to the storage tank.  It takes 1 minute to get the truck pump shut off and stop the flow from the truck.  492 lbs. are released into the tankwagon loading area dike.  Using the EPA OCA methodology, the material would evaporate at a rate of 1.89 lb./min., and would create an area with c 
oncentrations above the  toxic threshold out to a distance of 0.06 miles (317 ft.).  The list of potentially impacted receptors is: 
a. AFA Pallet property (lot next to the south fence line). 
 
Administration controls include inventory control, training, constant surveillance, preventive maintenance, and Process Safety Management measures.  Mitigation measures include the truck unloading containment dike, emergency response plan, training in spill control, and contacting of outside agencies and closest neighbors.      
 
2.  For ethylenediamine, an alternate scenario involves a failure of the unloading line while a tank wagon of the material is being unloaded to the storage tank.  It takes 1 minute to get the truck pump shut off and stop the flow from the truck.  262 lbs. are released into the tankwagon loading area dike.  Using the EPA OCA methodology, the material would evaporate at a rate of 44.1 lbs./min., and would create an area with concentrations above the  toxic threshold out to a 
distance of 0.06 miles (317 ft.).  The list of potentially impacted receptors is: 
a. AFA Pallet (lot next to the south fence line). 
 
Administration controls include inventory control, training, constant surveillance, preventive maintenance, and Process Safety Management measures.  Mitigation measures include the truck unloading containment dike, emergency response plan, training in spill control, and contacting of outside agencies and closest neighbors.      
 
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 
 
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals.  Our management systems address each of the key features of successful prevention programs including: 
 
*  Process safety information  
*  Process hazard analysis 
*  Operating procedu 
res  
*  Training  
*  Mechanical integrity 
*  Management of change 
*  Pre-startup review 
*  Compliance audits 
*  Incident investigation 
*  Employee participation 
*  Hot work permit 
*  Contractors 
 
As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: 
 
1. Trained personnel are stationed at the tank wagon unloading area during all tank wagon unloadings.  
2. Each chemical has a specific procedure for unloading it, with all necessary precautions and safety steps specified. 
3. Epichlorohydrin tank has a high level alarm with pump interlock, and a high/high level alarm. 
4. Ethylenediamine has high and high/high level alarms. 
5. Computer inventory control to maintain tank levels always below maximum capacity. 
 
These individual elements of our prevention program work together to prevent accidental chemical releases.  Our company and our employees are committed to the standard that these management systems set for the way we do business 
, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.  
 
FIVE-YEAR ACCIDENT HISTORY 
 
We keep records for all significant accidental chemical releases that occur at our facility.  The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: 
 
ethylenediamine     5 lbs.    3/18/98    no lost time  
 
For this incident, we have conducted a formal incident investigation to identify and correct the root cause of the event. 
 
EMERGENCY RESPONSE PROGRAM 
 
We maintain an Emergency Response Plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning.  Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations.  Furthermore, we coordinate our plan with the community emergency responders; the Newark 
Fire Department, HazMat team, NJDEP, and local medical emergency teams. 
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
There are no further improvements planned presently.   
 
CERTIFICATIONS 
 
Within the past five years, the process has had no accidental release that caused offsite impacts provided in the RMP rule (40 CFR 68.10(b)(1)).  No additional measures are necessary to prevent offsite impacts from accidental releases.  In the event of fire, explosion, or a release of a regulated substance from the process(es), entry within the distance to the specified endpoints may pose a danger to public emergency responders.  Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMPlan.  The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true accurate, and complete. 
 
For all other covered processes, the undersigned also certifies that, 
to the best of my knowledge, information, and belief, formed after reasonable inquiry, the other information submitted in this RMPlan is true, accurate, and complete. 
 
Name: Chris Ford 
Title:   V.P. Performance Improvement 
Date:  6/9/1999 
 
RMP DATA ELEMENTS 
 
The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide.  This information is categorized as follows: 
 
*  Registration 
*  Offsite consequence analysis 
*  Five-year accident history 
*  Program 2 prevention program 
*  Program 3 prevention program 
*  Emergency response program
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