Day-Glo Color Corporation - Executive Summary |
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A Risk Management Program (RMP) has been implemented at the Day-Glo Color Corporation for the reduction of accidental releases of hazardous materials. The RMP summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Risk Management Plan is organized to correspond with specific U.S. Environmental Protection Agency (EPA) RMP definitions and requirements, including: 7 Introduction; 7 Facility and regulated substances identification; 7 Hazard Assessment; 7 Prevention Program; 7 Five-Year Accident History; 7 Emergency Response Plan; and 7 Planned changes to improve safety. Introduction Risk management and safety are important concerns at Day-Glo; this RMP formalizes and documents these activities. Day-Glo is committed to conducting its operations in a safe and responsible manner and to reducing risks to human health and to the environment. Facility and Regulated Substanc e Identification The Day-Glo Corporation owns and operates a pigment manufacturing plant in Twinsburg, Ohio. Cyclohexylamine (CHA), a regulated toxic RMP substance with a threshold quantity for accidental release prevention of 15,000 pounds, is used at the facility as an ingredient in the pigment manufacturing process. The amount of CHA present in the system is approximately 55,000 pounds. Hazard Assessment - Worst Case Scenarios (WCS) The worst-case toxic accidental release scenario assumes the entire contents of the single 7500-gallon CHA storage tank are released into the diked area and evaporates at a rate of approximately 10 lb/min. EPA's SLAB guidance show that, under the worst-case weather conditions the release could travel 0.4 miles downwind until the toxic endpoint is reached. Hazard Assessment - Alternative Release Scenarios (ARS) The ARS for CHA also assumes that the entire contents of the storage tank is released inside the diked area and evaporates at a rate of 22 lbs/min. The release is estimated to go 0.08 miles. Prevention Program A prevention program is in place to minimize the risk of hazardous chemical releases in accordance the EPA Risk Management Program. This prevention program covers the CHA component of the manufacturing process in which CHA is present above the threshold quantity for RMP rules. The prevention program provides a structured approach to preventing accidents. Some of the specific activities in the prevention program include: 7 Process safety information is provided to all employees upon hire and is accessible at all times. 7 In-depth process hazard analyses are completed every five years by qualified personnel using techniques approved under the PSM standard. 7 Written operating procedures (kept up-to-date) are used for training and guiding the work of operators. 7 Training is provided to all employees upon hire, and refresher training is given annually or upon request. 7 Operators, mechanics, and contractor person nel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety. 7 Pre-startup safety reviews are conducted to insure that conditions for safe operation have been satisfied prior to starting new or modified equipment. 7 A program is in place to maintain the mechanical integrity of the process, which includes written procedures, training requirements, work orders, scheduled maintenance, and computerized documentation. 7 A hot work permit system assures that work is done safely and properly. 7 A management of change system is in place to ensure that changes are managed safely. 7 Incidents are investigated and actions are taken as part of a continuous improvement effort. 7 Routine audits are conducted to assure that safe practices are being followed. This systematic approach to process safety at Day-Glo involves employees and strives for continuing improvements in overall safety. The training, qualifications, and safety awarenes s of our operations, maintenance, and management personnel are a key element in reducing and mitigating accidents. Five-Year Accident History There have been no accidents/release of cyclohexylamine at Day-Glo which led to on-site deaths, injuries or significant damage in the past five years. There are also no reported incidents of off-site consequences from an accidental release of cyclohexylamine. Emergency Response Plan Day-Glo has an evacuation procedure to ensure that in the event of an emergency the personnel on-site know how to evacuate the area where the emergency is occuring. The procedure identifies assembly locations and a list of individuals to be contacted in order to mitigate the effects of a release. Because Day-Glo employees will not respond to cyclohexylamine emergencies, response activities have be coordinated with the Summit County Local Emergency Planning Committee and the local Fire Department. |