Valspar - Rockford Facility - Executive Summary |
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Accidental Release and Emergency Response Policies It is Valspar's policy to operate its plants in a manner that protects its employees, the public, and the environment. It is our policy to adhere to all applicable federal, state and local laws. The Valspar Rockford facility has a detailed, practiced Emergency Action Plan that is utilized to respond to any accidental release. Facility Description The Valspar Rockford Facility manufactures consumer paint, paint resin and water based colorants. The manufacturing process uses toluene diisocyanate as a raw material. The facility stores toluene diisocyanate in a 6,000 gallon storage tank and the maximum amount on site at one time is 60,720 pounds. The tank, which is isolated in a closed room within the building, was designed and built in accordance with sound and current engineering standards, local building codes, and state law. Worst Case Release Scenario As required by the RMP regulation, the worst case release scenario was cal culated by assuming the entire contents of the largest container were released. A rupture of the toluene diisocyanate storage tank was considered to be the worst case release scenario. This scenario is very unlikely due to the design and maintenance of the storage tank. The room was assumed to act as an enclosure that would retard migration of the volatilized toluene diisocyanate from the room. The effectiveness of the room as an enclosure was assumed to be 55 percent in accordance with USEPA guidance. The toluene diisocyanate was assumed to be contained within the dike formed by the walls of the room. According to EPA guidance for calculating the consequence of a toluene diisocyanate release, the distance to endpoint for a release of 60,720 pounds was calculated to be 21 feet or 0.004 miles. The EPA has determined that toluene diisocyanate does not pose a threat to the public at this distance. Because of limitations in the software provided by EPA, the distance of 0.1 miles had to be entered when in actuality, the distance was actually 0.004 miles. There are no public or environmental receptors located within this distance. General Accidental Release and Chemical Specific Prevention Programs The Rockford Facility has implemented the OSHA Process Safety Management Standard which is a systematic method of preventing accidental releases and complies with EPAs accident prevention rule. As such, the facility has completed a detailed analysis on the process to ensure the safe use and operation of the applicable equipment. Numerous safeguards are in place and include Operational Procedures, manual and automated control systems, safety interlocks, and other accepted good engineering and industry practices. The facility uses both procedural as well as technological systems to ensure safe handling of toluene diisocyanate. The toluene diisocyanate bulk storage tank is isolated inside a room within the plant. Should a leak in the tank occur, the toluene diiso cyanate would be contained within the room. The storage room is equipped with an electronic detection device that warns personnel of a release. All remaining tanks and piping that handle toluene diisocyanate are monitored by a second device. Both devices are equipped with a visible alarm and audible alarm. Toluene diisocyanate is delivered to the facility in bulk tank trucks. The truck is unloaded outside the storage room on a concrete pad with diked containment. The pad is sloped so that spills would drain into the toluene diisocyanate storage room. The facility has specific procedures for handling toluene diisocyanate and all personnel are trained on these procedures. Annual training is conducted on the chemical hazards of toluene diisocyanate . Five Year Accident History The Rockford Facility has never had an accident involving toluene diisocyanate that resulted in injuries, property damage or environmental releases. Emergency Response Program In the event of an emergen cy involving toluene diisocyanate , we will immediately notify the Rockford Fire Department and rely on their expertise to handle the situation. The fire department has a well-trained response team and is familiar with our processes. We have contracted with a qualified emergency response firm to aid in the cleanup of a release. Planned Changes to Improve Safety We have an ongoing and continuing process to update and review our manufacturing process for safety considerations. |