Manhattan Products, Inc. - Executive Summary |
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Manhattan Products, Inc. / Laundry Aids, Inc. is a manufacturer of laundry detergent, dish detergent, fabric softener, ammonia cleaner, and children's bubble solution in household sizes and strengths. We also manufacture most of the plastic bottles for use at our site. We blend our products and fill into consumer size bottles ready for shipment. We are regulated under the Clean Air Act Amendments of 1990, section 112 (r) and the New Jersey Toxic Catastrophe Prevention Act because of our use of anhydrous ammonia as a raw material for our ammonia cleaner. Manhattan Products has operated on this site since 1978. We are committed to the safe operation of our plant for the protection of our employees and the surrounding community. The ammonia process has undergone continuous improvement since its original installation. All of our chemical handling equipment and processes are designed and built to current industry standards and with safety and integrity as the primary focus. The com pany has invested a great deal in training, safety systems, equipment and installations, not only for ammonia but for all chemicals handled here, indicating management's commitment to safety. Our worst case scenario, which by regulation must be the complete release of the entire contents of our storage tank, resulted in a toxic endpoint concentration of 200 ppm at 3.2 miles, as calculated by the EPA's RMP Comp program. The tank capacity is 80,000 pounds, however administrative policy and written procedures do not allow the tank to be filled above 80% of capacity. This is considered in the scenario. There are no passive mitigation systems that would affect this scenario. Other protective measures have been taken to minimize the likelihood of this scenario. The tank is protected from collision by a double fence line and a steel barrier anchored in concrete. There are also written preventive maintenance procedures for the tank including periodic inspection and testing. The alternat ive release scenario chosen was a failure of a pressure relief valve on the tank. The endpoint concentration of 200 ppm was reached at 0.1 miles as calculated by RMP Comp. Mitigation systems were not considered since they would not be automatically activated in this scenario. This scenario was chosen because it may be more likely to occur and would also be a critical situation requiring deployment of the emergency response team. Two relief valves are manifolded together so that the failed valve can be shut off and replaced. The storage tank area is monitored by ammonia sensors placed around the tank, which sound an internal alarm when ammonia is detected. The tank is protected from overpressurization by two sets of two relief valves, which provide backup to each other, and by a water deluge system. The deluge system is designed to cool the tank to reduce the inside pressure. The deluge system is triggered by a pressure sensor when it reaches a pre-set level. There is also an i ndependent pressure switch to provide backup. There are safety interlocks, which during the ammonia batching process, will shut it down if specific abnormal conditions occur. Excess flow valves are located at each pipe connection to the tank to shut the flow if there is a break in the pipe downstream. An emergency unloading pump is installed to unload the contents of the tank into a tank truck if there is time enough to do so. Manhattan Products has been regulated under the Toxic Catastrophe Prevention Act since its origination in 1989. The ammonia process, equipment, and our RMP have been the subject of many comprehensive inspections by NJDEP chemical safety engineers. The most recent inspection was conducted on April 21st and 22nd, 1999. We are also regulated under the New Jersey Discharge Prevention, Containment, and Countermeasure rules, and the OSHA Process Safety Management standard. We have a detailed written operator training program in place with annual refresher traini ng for all ammonia operators. Our preventive maintenance program includes procedures for all equipment in the ammonia process line and emergency response equipment. Our RMP compliance audit will be completed prior to our TCPA anniversary date of July 22nd this year. Our most recent RMP audit, completed according to NJTCPA regulations, was submitted on 7/28/98. Our facility has not experienced any accidental releases of ammonia since its installation. Manhattan Products' emergency response program has been in place since 1989. The program includes procedures on notification of public responders and governmental agencies, and an organizational list of the emergency response team members with job duties and phone numbers for off-hours notification. Additional sections include information on first aid procedures, evacuation procedures, resources available, and a detailed description of the plant operation. Coordination with our local emergency planning committee is active and on going. Emergency response team personnel receive annual refresher training in possible scenarios, procedures, and notifications. Drills, involving a full scale deployment of the emergency response team are conducted annually. Improvements to safety controls and equipment are made on an on-going basis. In the last year we have replaced the ammonia sensors, pressure sensor, and pressure relief valves. This year, we have rewired and converted the safety control system to PLC based control. Additional safety improvements planned for the remainder of this year include replacement of the weather system and adding an ammonia sensor in the blending area of the plant. |