Tri-Con Industries, Ltd. Manufacturing Plant - Executive Summary |
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EXECUTIVE SUMMARY 1. SUMMARY OF OPERATION WHICH REQUIRES RMP Tri-Con Industries, Ltd. Manufacturing Plant is a recreational vehicle seat manufacturer. The scope of business includes injection molding, polyurethane foam production, vacuum forming, sewing and assembly. At the foam production department we use a mixture of 2,4 - Toluene Diisocyanate and 2,6 - Toluene Diisocyanate as a catalyst. There are two 5000 gallon tanks to hold a catalyst mixture and a polyol. Because we have more than minimum threshold for regulated substances, 2, 4 and 2, 6 - TDI, Tri-Con Manufacturing Plant is required to develop Risk Management Program. Based on the modeling done with RMP COMP and other factors, Tri-Con Manufacturing Plant is Level 2 program for those two chemicals. 2, 4 and 2, 6 - TDI is contained in the 5000 gallon holding tank, a 55 gallon day tank, piping system which connects the day t ank and the foam head and the foam head where the catalyst and the polyol are mixed and shot into a mold. The chemical is delivered from our supplier, Bayer, by a tank truck periodically. The maximum quantity of 2, 4 and 2, 6 TDI mixture that Tri-Con stores at any time is about 5000 gallons, which weighs about 50,000 pounds (2,4 - TDI 35,000 pounds, 2,6 - TDI 12,500 pounds respectively). 2. TRI-CON'S APPROACH TO CHEMICAL SAFETY Tri-Con's management is committed to minimize negative impact to the environment. As a way to ensure the chemical safety, Tri-Con is trying to be registered in ISO 14001. Through ISO 14001, we can achieve continual improvement by internal audit, corrective action and management review. Training is also an important part of ISO 14001. Work instruction is set up for certain processes. Deviation from the procedure and work instruction will be pointed out by internal audit , and the corrective action will take place. Maintenance program and emergency response procedures are also parts of ISO 14001 and strictly followed. Although ISO 14001 covers chemicals that are not part of this Risk Management Program, the process covered under Risk Management Program is one of the most important aspects. 3. THE WORST-CASE RELEASE SCENARIO AND THE ALTERNATIVE RELEASE SCENARIO THE WORST-CASE SCENARIO The worst case scenario for our situation would be a total release of TDI mixture from the 5000 gallon holding tank. There are several possibilities for this to happen, but we based our calculation on the scenario that the valve that is located at the bottom of the tank would rapture and the whole content would be spilled. The size of the possible rapture and the duration of the spill is described in the report. The holding tank is located in a dike tha t would hold the whole content from the tank. The modeling of dispersion was done using RMP COMP that we downloaded from the EPA web site. The storage tank is enclosed in the building and the dike that will hold the whole content of the tank , thus reducing the chance of release outside of the facility. THE ALTERNATIVE SCENARIO The alternative and most likely scenario is that the pipe that connects the day tank and the foam head would rapture and spill the chemical. The size of the possible rapture and the duration of the spill is described in the report. If this type of spill occurs, it would most likely be contained fairly quickly. As soon as we shut down the system, the pressure will be balanced and the spill will stop. What we would lose is the chemical that is in the piping system, which is about 10 gallons. The spill woul d happen in the foam production area where there is no mitigation system but enclosure. The modeling was done using the RMP COMP that we downloaded from the EPA web site. 4. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS As I mentioned earlier, Tri-Con Industries, Ltd. has a commitment to reduce negative environmental impact. The tool that we use is ISO 14001. ISO 14001 Manual and Procedures include process control, preventive maintenance and emergency response procedures. ISO 14001, would require Tri-Con Industries, Ltd. to achieve continual improvement by utilizing internal audit, corrective action and management review. Internal audit would point out any deviation from the required preventive maintenance program and emergency response procedures. When a non-conformance to ISO 14001 Procedures is found, the corrective action will take place and the problem will be solved. The management periodically reviews the result of internal audit and Manual/Procedure to improve on the system itself. General chemical safety for the process that applies to RMP is a part of this ISO 14001 system. We also plan to participate in voluntary compliance program offered by the State of Nebraska Department of Labor every year. An inspector will visit our facility and conduct an inspection. This program will help us identify unsafe conditions throughout the plant, as well as the department that has the covered process under RMP. Furthermore, our Safety Committee will conduct monthly inspection. 5. THE FIVE-YEAR ACCIDENT HISTORY We have not have any accident involving the covered process in the last five years. 6. THE EMERGENCY RESPONSE PROGRAM The emergency response program is set up for fire, tornado and chemical spill. The actual program in included in this report as a Microsoft Word text file. (emergency response procedure.txt) In the event of chemical spill of 2,4 - and 2,6 TDI, we will evacuate the plant. The initial response will be done by City of Lincoln Fire Department Hazardous Material team. The clean up will be contracted out to some firms that specialize in hazardous material clean up. We plan to have a chemical spill drill involving the HAZMAT team in the fall of 1999. We plant to conduct a drill at least once a year. 7. PLANNED CHANGES TO IMPROVE SAFETY We plan to register in ISO 14001 in the fall of 1999. Currently, we are setting up an Environmental Management System manual and procedures, and training our associates . The integrity of the process system will be checked more frequently and regularly. There is a slight possibility that we may switch to a different chemical with less 2,4 and 2,6 - TDI. |