Quest Separation Technologies, Inc. - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Quest Separation Technologies, Inc., we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency r esponse program * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certifications that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility Toll Manufactures Polyols, Polymers and Co-Polymers using a variety of chemicals and processing operations. Quest Separation Technologies, Inc. produces these products through batch reaction technologies utilizing state of the art equipment and controls. The company has the capability to manufacture such products from the raw material conponents all the way through packaging in solid and liquid forms. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental r elease: Toxics Allyl Alcohol Production of Polymer Resins 250,000 lbs. Propylene Oxide Production of Polyols 238,000 lbs. Flammables None of the listed flammable substances handled at this facility. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario and alternative release scenario for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemicals Allyl Alcohol: The worst case scenario for Allyl Alcohol involves the failure of Fresh Allyl Alcohol Storage Tank T-507 which is a 16500 gallon pressure vessel. This failure results in 90,800 pounds of Allyl Alcohol being spilled into the Tankfarm Containment Area, a diked concrete structure. The Allyl Alcohol will fill the existing trench and sump system and then spread across the concrete floor of the storage area. The conditions used for this scenario were the EPA OCA parameters for this substance using the Dense Plume Lookup Tables. No other mitigating controls or equipment were used. This scenario would impact off-site public receptors such as residences, schools, small businesses, recreational facilities and adjacent chemical plants. All Allyl Alcohol storage tanks are inside concrete diked containment. The area has a collection trench and sump with a sump pump to remove spilled material to alternative storage vessels. Each tank has a transfer pump capable of emptying the tank contents in about 90 minutes. The Allyl Alcohol storage tank is kept to a maximum volume of 80 % or 12, 818 gallons at any one time. Normal stora ge between campaigns is not more than 2000 gallons. All storage tanks have remote reading level transmitters and high level alarms to prevent accidental overfill. All vessels have nitrogen blanketing and automatic pressure relief valves discharging to the flare header. Alternative Release Scenario - Regulated Toxic Chemicals Allyl Alcohol: The Alternate Scenario involves a leak of Allyl Alcohol from a failed ball valve in the pump suction of Transfer Pump P-554 during a batch transfer to Reactor R-101. The Bleed Valve is a 3/4" ball valve with standard trim which would cause a leak proportional to a 1/2" hole. We assumed that the operator assigned to the task was called away from the tank where he would normally remain until the 30 minute transfer was complete. We also assumed that the pump would provide enough flow that the automatic low flow shutdown would not activate and trip the pump and control valves. All of the material spilled would be contained in the trench and sump syste m and the suction block valve would be closed 15 minutes after the spill was discovered. The spilled Allyl Alcohol would be transferred from the sump to a storage tank and the trenches washed with water to remove residual material. The Toxic Endpoint was calculated using the EPA OCA method. No public receptors of any type would be affected by this more likely release scenario. No other mitigating controls or equipment were used for this scenario. Worst-case Release Scenario - Regulated Flammable Chemicals No RMP listed flammable chemicals are stored on site at this time. Alternative Release Scenario - Regulated Flammable Chemicals No RMP listed flammable chemicals are stored on site at this time. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive appro ach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: 1. All storage tanks are equiped with level and pressure transmitters and alarms. 2. All storage vessels are minimum 15 psig rated, automatic pressure controls and rupturedisks are provided to prevent tank rupture due to overpressure. 3. All reactors used in Allyl Alcohol or Propylene Oxide service have redundant pressure relief valves that vent to a 16,500 gallon liquid knockout vessel prior to venting to the plant flare. This prevents a r elease of liquid from the flare due to any upset conditions. 4. Reactor vessels in Allyl Alcohol or Propylene Oxide service have control interlocks for raw material flow, temperature, high pressure, differential temperature and pressure, agitator operation and Cooling Water pump operation. These all serve to prevent release due to upsets or uncontrolled reactions. 5. Storage tanks in Allyl Alcohol service are limited by administrative controls to a maximum volume of 80% of capacity and the volume of pure Allyl Alcohol between campaign is reduced to 2,000 gallons. 6. Storage of Propylene Oxide is limited to 80% of full volume administratively and 85% maximum volume by automatic level control devices. The storage vessel level is lowered to a maximum level of 3,000 gallons between product campaigns. 7. All reactor vessels and piping are pressure and vacuum tested prior to project startup as part of the Safe Operating Procedure. 8. Fugitive emissions testing is conducted on all equipm ent in VOC service on a minimum of a quarterly basis. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: Quest Separation technologies, Inc. has not had any accidental releases in excess of the Reportable Quantities of any chemicals covered under the RMP rule in the past five years. EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regu latory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: 1. Improved handling of process catalysts and provide individual training on handling each catalyst. 2. Revise the relief valve system on the catalyst storage tank. 3. Ship all catalyst in bulk and return unused portions to alleviate safety concerns associated with long term catalyst storage. 4. Ground proving indicators will be installed at Allyl Alcohol unloading station. CERTIFICATIONS Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental release scenario for the following process(es) is less than the distance to the nearest public receptor: Within the past five years, the process(es) has (have) had no accidental release that caused offsite impacts provided in the RMP rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from the process(es), entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMPlan. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true accurate, and complete. For all other covered processes, the undersigned also certifies that, to the best of my knowledge, information, and belief, formed after rea sonable inquiry, the other information submitted in this RMPlan is true, accurate, and complete. Signature Title Date RMP DATA ELEMENTS The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows: * Registration * Offsite consequence analysis * Five-year accident history * Program 2 prevention program * Program 3 prevention program * Emergency response program |