Air Products and Chemicals, Inc. - Executive Summary |
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Accidental release prevention and emergency response policies Epoxy additives are the main product line manufactured at this facility. Epichlorohydrin in the amounts handled by our facility is 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 device (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. Our emergency response plan includes procedures for the notification of the local fire authority and other resources so that appropriate measures can be taken by local eme rgency responders to control accidental releases. This document has been prepared in accordance with the EPAs Risk Management Plan regulation (40 CFR, Part 68). The substances and processes considered during the preparatin of this RMP and the scenarios described were selected based on criteria established in the regulation. Facility Description and Regulated Substances Handled The primary purpose of this facility is to manufacture epoxy additives. One of the product lines manufactured is the diluent product line. Diluents are sold to others for use as modifiers in two part epoxy systems. The plant manufactures a number of diluents all of which use Epichlorohydrin as a raw material. Epichlorohydrin is delivered to the facility by tank truck and stored on site. It is combined with an alcohol in the presence of a catalyst at elevated temperature in the first of three steps required to make diluent products. Epichlorohydrin is the regulated substance that is handled at this fa cility. It is handled in several different situations. The situation covered by the regulation is as follow: - Storage of 115,000 pounds of liquid Epichlorohydrin at ambient conditions Worst Case and Alternate Case Release Scenarios The "worst-case scenario" as defined by the EPA for a release of Epichlorohydrin is the rapid release of the entire 115,000 pounds of epichlorohydrin at ambient temperature from a storage tank in in a diked area. The maximum distance to the EPA defined endpoint for this worst case scenario is 0.4 miles. Passive mitigation measures were taken into account in evaluating this worst case scenario. The "alternative case scenario" as defined by the EPA for the release of Epichlorohydrin is the release due to a flange gasket failure on the line from the Epichlorohydrin Storage Tank. The maximum distance to the EPA defined endpoint is <0.1 miles. Passive mitigation measures were taken into account in evaluating this worst case scenar io. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The facility developed prevention program elements based on the Federal EPAs Accidental Release Prevention Plan and OSHAs Process Safety Management (PSM) regulation. This facility was designed and constructed to comply with applicable state and industry codes. Five Year Accident History No accidents involving the accidental release of Epichlorohydrin that resulted in any deaths, injuries, or significant property damage on site or know off-site deaths, injuries, evacuations, sheltering in place, property damage or environmental damage have occurred at this facility. Emergency Response Program The facilitys emergency response program is based on 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. The employees receive annual refresher taining in their role in the emergency plan. Emergency response activities have also been coordinated with the Cumberland Fire Department for releases of toxic materials. Periodic drills are condected with agencies to review the effectiveness of our emergency procedures. The last drill held was with the Cumberland Fire Department in November of 1998. Planned Changes to Improve Safety At this time there are no major administrative, operational, process or equipment changes planned for this facility. |