ZENECA RESINS - WILMINGTON PLANT - Executive Summary |
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ZENECA Resins' Wilmington, MA plant (ZENECA) makes polymer products such as polyurethane and acrylic resins that are used in paints and other products. The facility uses 2,4- toluene diisocyanate (TDI) and 2,6 TDI, and stores these materials as a mixture in an aboveground storage tank, equipped with a spill-containment dike. During the manufacturing of certain products, the TDI is transferred from the tank into the manufacturing area through steel pipes. Because of the amount of TDI that is stored at the facility, ZENECA must comply with the Environmental Protection Agency's Risk Management Program (RMP) standard, and must complete and submit a Risk Management Plan. As required by RMP, facilities like ZENECA that store certain chemicals in large quantities must develop "worst-case" scenarios that describe possible releases and include an offsite consequence analyses (OCA), which basically estimates the impact to the surrounding community. In developing this Risk Management Plan, EPA's OCA Guidance dated May 24, 1996 was used to perform off-site consequence analyses for TDI. Following this guidance for the worst-case scenario, it was assumed that the entire contents of the TDI storage tank release into the containment dike, which is designed to capture the entire contents of the tank. By containing the entire spill, the dike prevents the spilled material from forming a large pool, and thereby limits the surface area from which the TDI mixture could evaporate. Using mathematical formulas and lookup tables provided in the Guidance, we determined that the impact of this worst case scenario reaches 0.06 miles from the tank. The area within this distance does not include receptors of any kind. RMP also requires that facilities provide information regarding reportable releases that have occurred within the past 5 years. ZENECA has not had a reportable accident involving TDI in that time. Since it was determined that a TDI release would not affect receptors, and that the facility has not had a reportable spill of TDI in the past 5 years, ZENECA meets the requirements of RMP's Program 1, which is designated to facilities that pose the least amount of risk. ZENECA Resins' management is deeply committed to the safe, efficient operation of its processes and actively solicits suggestions for improvement from employees, contractors, vendors, and the public. In accordance with other governmental regulations, and as a best management practice, ZENECA has instituted several environmental, health and safety (EHS) programs and corporate policies. These include a Spill Prevention Countermeasures and Control Plan, Contingency Plan, Emergency Action Plan, and Fire Prevention Plan. Per the Occupational Safety and Health Administration's (OSHA) Process Safety Management standard, ZENECA has performed a Process Hazard Analysis (PHA) of its manufacturing equipment, and has trained its employees on established safety procedures for working with chemicals including TDI. Safety controls and modern safety devices are installed on various process equipment to further reduce the likelihood of a release. Per corporate management policy, any proposed change in equipment or material must be approved by several management staff prior to instituting that change. This policy requires that personnel responsible for EHS matters be included in the approval process. ZENECA has specifically conducted a PHA for TDI and has installed protective systems to minimize the chances of a release, mitigate any release that may occur, and maintain the integrity of these systems. Written operating and maintenance procedures and operator training programs are in place and are kept current through a systematic review process. All incidents involving the process are promptly identified and investigated. But, as already mentioned, in the last five years, there has not been a reportable accident involving TDI. The facility has voluntarily formed an in-plant Emergency Resp onse Team and Incident Command System, and maintains spill control equipment on site. Members of the team are trained annually per OSHA regulations. The most recent training was conducted in April 1999. The facility has designed specific response procedures in cooperation with the Wilmington Fire Department, who is frequently invited into the plant and participates in periodic drills. In addition, ZENECA has coordinated its response efforts with the local Hazardous Materials (HAZ-MAT) Team, who has also toured the facility. Through other EHS regulations, ZENECA has also communicated with the Local Emergency Planning Committee, and the State Emergency Response Commission. Please Note: Due to input limitations of EPA's RMP*Submit software, the actual spill durations and release rates could not be entered. However, values were inputted as directed by the EPA. For 2,4 TDI, the actual release rate is 0.0090 pounds per minute and the actual spill duration is 8,500,000 minutes. For 2, 6 TDI, the actual release rate is 0.033 pounds per minute and the actual spill duration is 590,000 minutes. |