ORTEC, INC. - Executive Summary |
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ORTEC, INC. General Executive Summary I. Accidental Release Prevention and Emergency Response Policy Ortec, Inc. is strongly dedicated to employee, public and environmental safety. This committment to safety starts with our senior management staff and filters down throughout our entire organization. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Our comprehensive accidental release prevention program covers areas such as design, installation, operating procedures, maintenance, and employee training associated with regulated processes at our facility. II. The Stationary Source and the Regulated Substance Handled Ortec, Inc. is a custom chemical manufacturer. Our primary business includes various adhesives, coating polymers, and similar polymers. We presently have one regulated toxic substance present at our facility. This substance is Acrylonitrile [2-Propenenitrile]. Acrylonitrile is a raw material used in making our polymers. Acrylonitrile is stored in an 8,000 gallon storage tank. The maximum inventory for Acrylonitrile at our facility is 46,900 pounds. III. The Worst Case Release Scenario 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 RMP*Comp Version 1.06. The following paragraphs provide details of the chosen scenarios. The worst case scenario submitted for Program 3 toxic substances involves a catastrophic release of Acrylonitrile. The scenario release amount is 46,900 lbs of Acrylonitrile. Toxic liquid is assumed to be immediately released to form a pool, from which evaporation takes place. The entire pool is estimated to have evaporated over 536 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.7 miles is obtained corresponding to a toxic endpoint o f 0.076 mg/L. The alternative release scenario for Acrylonitrile involves a release from ST#34, the Acrylonitrile storage tank. The scenario involves the release of 36,000 lbs of Acrylonitrile. Toxic liquid is assumed to be immediately released to form a pool, from which evaporation takes place. The entire pool is estimated to have evaporated over 360 minutes. At Class D atmospheric stability and 3 m/s windspeed, the maximum distance of 0.3 miles is obtained corresponding to a toxic endpoint of 0.076 mg/L. Dikes are used as passive mitigation control and are taken into account to calculate both scenarios. Control measures in place but not considered in the scenarios include: the manual application of foam to suppress Acrylonitrile vapors and the manual application of sodium metabisulfite to neutralize spills. The tank is also enclosed in a 16' x 16' sealed concrete walls. This concrete enclosure limits the exposed surface area of a pool and thus the release rate is most proba bly less than the release rate reported in the scenarios. Plastic sheeting is made available to cover spills, thereby limiting vapor releases. Written operating procedures and a high-level alarm prevent more than 7,000 gallons from being present in the 8,000 gallon tank. The tank is inspected for signs of leaks or damage weekly by maintenance personnel and every 4 hours by operations supervision. IV. 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 outlined in 40 CFR part 68 of the EPA regulations. Our facility also meets the requirements of the OSHA PSM rule. For our covered process, a pre-startup review was conducted along with specific training by the supplier on the handling of Acrylonitrile. All of our affected employees are trained yearly on the hazards associated with Acrylonitrile and safe handling practices. Only d esignated senior employees are qualified to unload Acrylonitrile into our bulk storage tank. The following sections briefly describe the elements of the release prevention program that is in place at our facility. Process Safety Information Ortec, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all covered processes. We maintain current MSDSs for all our raw materials and products. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and properly controlled. Depending on the process, we use both the Hazard and Operability Study and Checklist methodologies to carry out these analyses. The studies are undertaken by a team of qualified personnel with expertise in engineering, maintenance, safety, and process operations and are revalidated at a regular interval of 3 years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures Ortec, Inc. maintains written operating procedures in order to safely conduct activities within our covered process. The procedure for Acrylonitrile tanker unloading addresses personal protective equipment required, abnormal conditions, and emergency equipment/supplies requirements. This procedure is regularly reviewed and used by the operators each time an Acrylonitrile tanker is unloaded. Training Ortec, Inc. has a comprehensive training program in place to ensure that employees who handle Acrylonitrile are competent in safe handling practices to protect themselves and their surroundings. Refresher training is provided on Acrylonitrile handling at least yearly and more frequently as needed. Air monitoring is also conducted periodically during unloading operations to ensure that workers are not being overexposed. The results are posted for all employees to review. Comprehensive training is also con ducted specifically for unloading of Acrylonitrile tankers into our bulk storage tank. Safety procedures and alarms are reviewed during this training. Additionally, employees are trained on RCRA regulations so they are environmentally aware. Mechanical Integrity Ortec, Inc. carries out documented maintenance inspections on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; storage tanks, piping systems, relief and vent systems, and pumps. Maintenance operations are carried out by qualified personnel with 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 Ortec, Inc. to manage changes in process chemicals, technology, equipment and procedures. 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-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Ortec, Inc. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Incident Investigation Ortec, Inc. truly believes that process safety management and accident prevention is a team effort. By participation in the Ortec Safety Committee, 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 p articular. Five-year Accident History Ortec, Inc. 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 reportable release of Acrylonitrile during this period. Emergency Response Plan Ortec, Inc. 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. Pickens County LEPC is the Local Emergency Planning Committee with which our emerg ency plan has been coordinated and verified. Additionally, representatives from the Easley Fire Department are invited to tour the facility yearly. IIV. Safety Improvements To ensure more regular training of our employees, Ortec,Inc., has increased the safety training staff. Employees are routinely trained in chemical hazards and chemical release prevention methods. Ortec, Inc. is also proactive in the area of process safety by conducting hazard analyses on all major processes even when not specifically required by law. . |