CONAP, INC. - Executive Summary |
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Conap (a) ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Cytec is a leader among chemical manufacturers in its safety, health and environmental programs. Our commitment to protect our employees and the communities that are home to our operations is an integral part of Cytec's way of doing business. Cytec has established safety, health, emergency response and environmental policies and standards to meet or exceed all regulatory requirements. As a member of the Chemical Manufacturers' Association (CMA), Cytec subscribes to the codes established for Responsible Care .. (b) THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED Our facility has one process that produces prepolymers which are used to make polyurethanes. The regulated substance involved with this batch operation is toluene diisocyanate. (c) WORST-CASE RELEASE SCENARIO AND ALTERNATIVE RELEASE SCENARIO The toxic worst-case scenario is the failure of a storage tank and the release of 50,800 pounds of toluene diisocyanate. The mitigating effects of a dike and an enclosure were included in the evaluation of the possible consequences. The cloud formed by the evaporating toluene diisocyanate would not reach off-site endpoints and nearby public and environmental receptors. [Due to minimal allowable entries in the RMP Submit software, both release rate (section 2.6) and Distance to endpoint (section 2.11) are overstated. The rate minimum is 1 lb/min, and the actual rate is 0.0047 lb/min. The endpoint minimum is 0.2 miles, while our endpoint is 87 feet, or 0.016 miles.] Since the worst-case scenario has no effect beyond our fenceline and there have been no releases that had off-site effects, the toluene diisocyanate process falls into program level 1. The regulation does not require the identification of alternative release scenarios for program level 1 processes because they would not have off-site effects. (d) THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-S PECIFIC PREVENTION STEPS The regulation does not require program level 1 processes to have an accidental release prevention program. However, through compliance with the following internal requirements and other regulations, Conap does have a comprehensive program. - Cytec Safety, Health, Environmental and Engineering standards - New York State "Preparedness, Prevention, and Contingency (PPC) Plan as defined in 6 New York Code of Rules and Regulations (NYCRR) Part 373-2.3 "Preparedness and Prevention" and Part 373-2.4 "Contingency Plan." - Federal Environmental Protection Agency's "Spill Prevention, Control, and Countermeasures (SPCC) Planning requirements pursuant to 40 Code of Federal Regulations (CFR) Part 112 "Oil Pollution Prevention." - New York State Chemical Bulk Storage Regulations (6NYCRR) Part 598.1(k) "Spill Prevention Report." - Generally recognized & accepted engineering codes and standards, and The following specific engineering and administrative controls help prev ent a release of toluene diisocyanate. - Piping replacement to upgrade to stainless steel welded piping - Gasket upgrade to 300 PSI, TDI compatible - Valve replacement, with "fail-closed" actuators - New control scheme to alert when backup safety controls have failed - Resealing of containment walls. - Installation of remote television monitor for leak detection - Valve control change to reduce forces in piping during valve closing - Heat tracing for piping, with optimized temperatures. - New Transfer Station, with built-in containment - Pipe chase containment between Transfer Station and Bulk Storage - Double valving end-of-pipe connections - Chemically compatible, coded gaskets/flanges - Bar-coded Inventory system with checks on tank inputs/outputs - Confirmation of sufficient head-room for the load to be off-loaded - Daily Inspections for leaks - Annual and 5-year Inspections of the complete storage system - Preventive Maintenance - Off-loading procedures with steps for leak pre vention (e) 5-YEAR ACCIDENT HISTORY There have been no incidents at the Conap Plant that meet the criteria for reporting in the five-year accident history. (f) EMERGENCY RESPONSE PROGRAM CONAP has developed a "Consolidated Spill Prevention and Emergency Response (CSPER)" Plan as outlined in section 4. This plan is coordinated with local emergency response through the Cattaraugus County Local Emergency Planning Committee. Copies of the plan are provided to local fire and police departments, as well as privately contracted emergency responders. The plan defines individual responsibilities and tasks during various emergencies. CONAP provides training appropriate to the level of involvement to all employees. During emergencies involving spills, CONAP employees are asked to report the event, provide key information on the type and extent of the emergency, and follow the Emergency Coordinator's instructions to stabilize processes, control employee access to affected in plant areas , and control immediate access to the facility by visitors, contractors and off-shift employees. The Emergency Coordinator, or backups, direct this first response, and make timely notifications to local responders and the Emergency Response Contractor. When local emergency responders arrive, the Emergency Coordinator provides on-site assistance and support. Spill Response, including all clean-up and remedial operations, is the responsibility of the Emergency Response Contractor. The Plan defines notifications to Local, State and Federal Agencies, as well as the Public. (g) PLANNED CHANGES TO IMPROVE SAFETY CYTEC Industries is constantly striving to upgrade its processes, control technology, employee training, inspection, repair and maintenance of process equipment in order to improve safety. We are also executing a well organized plan to ensure minimum possible negative impact from Y2K. - Replacement of storage tanks to meet API 650 Standard - Replacement of containment to in clude tertiary containment barrier - Installation of new high level and high pressure alarms, with automatic shutdown - Addition of second remote television monitor |