GenFoam, LP - Executive Summary |
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In accordance with EPA Risk Management Program regulations (40CFR68), GenFoam, LP-El Paso has implemented an accidental release prevention program. The facility manufactures flexible polyurethane foam by mechanical mixing of polyols with Toluene Diisocyanate along with water, catalysts, surfactants and other chemical constituents. The resulltant polymeric network is expanded with carbon dioxide formed from the reaction between the water and the TDI. The facility stores and uses quantities of Toluene Diisocyanate in excess of the threshold quantities specified in 40CFR68.115, which is 10,000 pounds. The process, Foam Production and Railcar Unloading, is inventoried for 587,200 pounds of TDI which is held in two bulk storage tanks and a railcar which are completely contained within the facility. A worst case release scenario for the facility would be a complete rupture of a 30,000 gallon bulk storage tank to an enclosed, diked area. Toxic chemical dispersion is calculated at 38.7 feet . An alternate release scenario is the rupture and loss of contents of a chemical transfer hose in the railcar unloading area. The toxic chemical dispersion is calculated at 31.2 feet. All release calculations were performed using ALOHA air modeling software and EPA's RMP Off-site Consequence Analysis Guidence document. Other release scenarios were also evaluated. The following elements are part of GenFoam's Prevention Program: Process Safety Information which includes toxicity, process flow, process chemistry and process design information. Process Hazard Analysis was conducted to review the hazards associated with the regulated substance, procedures and potential equipment failures/human errors which can possibly result in a release. Results and recommendations will be updated per the specifications in 40CFR68.50. Standard Operating Procedures (SOP's) have been developed to ensure process activities are safely conducted and are consistant with the standard safety information. All SO P's are checked and verified for correctness. Preventative Maintenance is delegated to Plant Engineering. The program consists of equipment lists and specifications, instrument lists, pipeline specifications, equipment history and repair records, preventative maintenance procedures and work orders. Compliance Audits are conducted by facility management with the aid of Regulatory Affairs. Deficiencies are documented and scheduled for improvement as needed. Incident Investigations ollow guidelines for fact determination, root cause analysis and resolution for incidents that may have resulted in a catastrophic release. Release and chemical specific prevention used at the facility include relief valves, check valves, manual and automatic shutoffs, interlocks, audible and visual alarms, TDI handling SOP's, bypass piping, rupture disks and blowout containers. Mitigation systems include sprinkler systems, chemical neutralization, diking and enclosures. The process and unloading areas can be monitored by portable TDI detection devices. Operator training is conducted as needed. The facility has not had any accidental releases which have impacted off-site receptors. The facilities emergency response plan defines the response organization, coordination with city, county, state and contracted emergency response organizations, equipment available on-site, response procedures, training, notification procedures and drills. The plan will be updated as needed. GenFoam is committed to the responsible handling of hazardous chemicals in its possession and for our responsibility to protect the environment and the health and safety of our employees and the surrounding community. |