Tadco Chemical Co. - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Tadco Chemical Co. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Polyol Manufacturing. We have 2 regulated substances present at our facility. These substances include Propylene oxide [Oxirane, methyl-] and Ethylenediamine [1,2-Ethanediamine]. Propylene oxide [Oxirane, methyl-] is the reactant in our batch process. Ethylenediamine [1,2-Ethanediamine] is t he starter material reacted with Propylene oxide. The maximum inventory of Propylene oxide [Oxirane, methyl-] at our facility is 186300 lb. while Ethylenediamine [1,2-Ethanediamine] is present at our facility in a maximum quantity of 41,000 lb.. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), 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 OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from the Propylene Oxide tank. In this scenario 186,300 lb. of Propylene oxide [Oxirane, methyl-] is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is est imated to evaporate over 427.62 minutes. Passive mitigation systems such as dike(s) are also taken into account to calculate the scenario. These mitigation systems have the effect of containing an accidental release. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.1 miles is obtained corresponding to a toxic endpoint of 0.59 mg/L. The alternative release scenario for Propylene oxide [Oxirane, methyl-] involves a release from the Propylene oxide tank. The scenario involves the release of 40180.74 lb. of Propylene oxide. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 74.04 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of containing an accidental release. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.59 mg/L of Propylene oxide [Oxi rane, methyl-] is 0.25 miles. The alternative release scenario for Ethylenediamine [1,2-Ethanediamine] involves a release from the Ethylenediamine tank. The scenario involves the release of 41,000 lb. of Ethylenediamine. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 5325.77 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of containing an accidental release. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.49 mg/L of Ethylenediamine [1,2-Ethanediamine] is <0.06 miles. 4. 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 set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance w ith NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Tadco Chemical Co. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is HAZOP. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of every five years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 08/23/1996. Operating Procedures For the purposes of safely conducting activities within our cov ered processes, Tadco Chemical Co. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Tadco Chemical Co. has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed. Mechanical Integrity Tadco Chemical Co. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief systems, emergency shutdown systems, controls and pumps . Maintenance operations are carried out by qualified personnel with previous 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 Tadco Chemical Co. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 03/15/1999. 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 Tadco Chemical Co.. The most recent review was performed on 5/15/96. These reviews are co nducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Tadco Chemical Co. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 05/07/1999. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Tadco Chemical Co. promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Tadco Chemical Co. truly believes that proce ss safety management and accident prevention is a team effort. Company 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 particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Tadco Chemical Co. has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Tadco Chemical Co. has had an excellent record of preve nting accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Tadco Chemical Co. 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. Los Angeles Cty Fire Dept is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Contract Employees Tadco Chemical Co. is a Subc hapter S corporation and has no employees. Process control operator is employed on an as needed basis from T. A. Davies which shares the facility woth Tadco Chemical Co. |