Air Products and Chemicals, Inc. - Executive Summary |
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Federal RMP Executive Summary Air Products and Chemicals, Inc. Paulsboro, New Jersey Facility 1. Accidental release prevention and emergency response policies: At this facility, we manufacture polyurethane catalyst and prepolymers. Toluene diisocyanate and Pentane in the amounts handled by our facility, are considered hazardous by the EPA. It is our policy to adhere to all applicable Federal and state rules and regulations. Air Products manages the safety of the regulated processes by means of operating procedures, equipment testing and inspections, safety devices (e.g., alarms, shutdowns, instrumentation, relief devices) inherent in the design of this facility and other controls and systems designed to prevent accidental releases of hazardous chemicals. Safe work practices and training of our personnel supplement the inherent safe design of the plant. Our emergency response program is based upon OSHAs HAZWOPER regulation. The emergency response plan includes procedures for the notification of the local fire authority and outside responders so that appropriate measures can be taken by local emergency responders to control accidental releases. This document has been prepared in accordance with the EPAs Risk Management Plan regulation (40 CFR, Part 68) and the New Jersey Toxic Catastrophe and Prevention Act (N.J.A.C. 7:31). The substances and processes considered during the preparation of this RMP and the scenarios described were selected based on criteria established in these regulations. 2. The stationary source and regulated substances handled: The primary purpose of this facility is the manufacture of polyurethane catalyst ( DABCOd) and prepolymers. Toluene diisocyanate is used to manufacture the prepolymer products and is received and stored on-site in an aboveground storage tank. Pentane is used in the manufacturing of our DABCO catalyst and is also received and stored onsite in aboveground storage tank. The maximum amounts of the regulated s ubstances stored in tanks and processing equipment combined at this facility are: 7 410,000 pounds of toluene diisocyanate 7 142,470 pounds of pentane 3. The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distance for each reported scenario: The "worst-case scenario" ( WCS), as defined by the EPA, associated with a release of flammable pentane is a vapor cloud explosion (VCE) involving the maximum inventory of pentane contained in the aboveground storage tank. The full pentane inventory of 101,000 pounds is assumed to be released into a diked area which serves as passive mitigation. The portion evaporates in 10 minutes and ignites, resulting in a VCE. The maximum distance to the EPA defined endpoint (1 psi overpressure) for this WCS reaches public receptors. Although we have active controls directed at preventing such a release and controlling the consequences, no credit for active mitigation measures were taken into account in evaluating this WCS. The "alternative case scenario" (ACS) for flammable pentane at this facility is a pool fire resulting from a drain valve leak. The amount of pentane assumed to be released is 9,360 pounds. The maximum distance to the EPA defined flammable endpoint for this ACS reaches public receptors. No active or passive mitigations were considered in evaluating this ACS. The WCS, as defined by the EPA, associated with a release of toxic toluene diisocyanate is the release of the maximum inventory of toluene diisocyanate contained in the aboveground storage tank into a diked containment area. This full inventory of 235,000 pounds is assumed to be all released in 10 minutes. The maximum distance to the EPA defined endpoint for this WCS reaches public receptors. Although we have active controls directed at preventing such a release and controlling the consequences, no credit for active mitigation measures were taken into accou nt in evaluating this WCS. The ACS for toxic toluene diisocyanate at this facility is a 2 inch charge line leak. The amount of toluene diisocyanate assumed to be released is 30,600 pounds. The maximum distance to the EPA defined toxic endpoint for this ACS reaches public receptors. No active or passive mitigations were considered in evaluating this ACS. The actual release rates for the WCS and ARS for the toxic material is less than the release rates entered in Sections 2 and 3 of the RMP Submit. The release rate entered in Sections 2 and 3 is the minimum entry that can be input into this field. 4. The general accidental release prevention program and specific prevention steps: The facility developed prevention program elements based on the Federal EPAs Accidental Release Prevention Plan, the New Jersey Toxic Catastrophe and Prevention Act ( NJ TCPA), and OSHAs Process Safety Management (PSM) regulation. This facility was designed and constructed to comply with applica ble state and industry codes. 5. Five-year accident history: There have been no accidents involving accidental release of TDI or pentane within the last 5 years that resulted in any deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.. 6. The emergency response program: The facilitys emergency response program is based upon OSHAs HAZWOPER standard. At this site, employees are trained to recognize emergencies and initiate emergency response from outside agencies. They have been trained to OSHAs First Responder Awareness Level and First Responder Operations Level. The employees receive annual refresher training in their role in the emergency plan. Emergency response activities have also been coordinated with the local Fire Department for incidents related to both regulated chemicals. Periodic drills are conducted to review the effectiveness of our emergency pr ocedures. 7. Planned changes to improve safety: The facility resolves recommendations from PHAs and Incident Investigations, some of which may result in modifications to the plant design and operating procedures. However, at this time no major administrative, operational, process, or equipment changes are planned for this facility. |