Pacific Epoxy Polymers, Inc. - Executive Summary |
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General Executive Summary for Pacific Epoxy Polymers, Inc. 1. Accidental Release Prevention and Emergency Response Policies We at Pacific Epoxy Polymers, Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with Richmond Fire Department which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Development, manu facture and supply of raw materials for the epoxy resin formulator.. We have 2 regulated substances present at our facility. These substances include Epichlorohydrin [Oxirane, (chloromethyl)-] and Formaldehyde (solution). The regulated substances at our facility are involved in several uses. Epichlorohydrin [Oxirane, (chloromethyl)-] is used for producing reactive diluents. Formaldehyde (solution) is used for producing chemical resistant epoxy hardener. The maximum inventory of Epichlorohydrin [Oxirane, (chloromethyl)-] at our facility is 230,000.00 lb. while Formaldehyde (solution) is present at our facility in a maximum quantity of 5000.00 lb.. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenario. Scenario: The Epichlorohydrin spill. Pacific Epoxy Polymers receives its epichlorohydrin from tank wagons that come in without any pressure on them and are equipped with only dry disconnect valves. If the vessels come in with pressure, the operator in charge of the unloading has to carefully release the pressure through controlled measures to avoid a hose from being blown off. If by chance the pressure gauge was reading zero pounds of pressure and the actual pressure inside the vessel was over 15 pounds of pressure, an accidental release of epichlorohydrin could occur. The operator, following the guidelines to offload epichlorohydrin, checks to see if the wagon has pressure and reads zero pounds. As he opens the valve to start pumping the raw material into the bulk storage tank, the pressure built up inside the vessel blows the hose off the tank wagon spraying epichloro hydrin inside the building. Remedy: The first thing the operator would have to do is to close the valve on the wagon using the emergency shut off valve located near the front of the tank wagon if he can get to it without putting himself in more danger. Then evacuate the area and notify all personnel of the immediate dangers associated with the incident and evacuate the buildings. Using the Emergency Response plan, that Pacific Epoxy Polymers created for a step by step guide dealing with an emergency situation, notify the proper authorities and agencies for the necessary clean up. While waiting for the Hazwop team to arrive, the plant personnel with the help of the Richmond Fire Department would set up boundaries to keep harm from any individual. MSDS's would be distributed to the incoming Hazwop team and a decontamination center would also be set up. Once the Hazwop team arrives, the authority would be transferred from Pacific Epoxy Polymers to them with the employees standing by to assist if needed. Prevention: The employees, that are trained to off load epichlorohydrin, have been informed of the possible dangers that are associated with these trucks. The employees check all gauges and if they suspect that a gauge is wrong, then the truck is rejected or inspected by a more trained individual. Scenario: The Formaldehyde Spill A tote of formaldehyde had a faulty valve which gave way during the weekend allowing the 5000 pounds of 37% formaldehyde to spill onto the floor. The maintenance walks into this situation on Sunday then immediately evacuates the area. Remedy: The first thing the maintenance man would do is to evacuate the area and notify all personnel of the immediate dangers associated with the incident. Using the Emergency Response plan, that Pacific Epoxy Polymers created for a step by step guide dealing with an emergency situation, notify the proper authorities and agencies for the necessary clean up. While waiting for the Hazwop team to arrive, the plant personnel with the help of the Richmond Fire Department would set up boundaries to keep harm from any individual. MSDS's would be distributed to the incoming Hazwop team and a decontamination center would also be set up. Once the Hazwop team arrives, the authority would be transferred from Pacific Epoxy Polymers to them with the employees standing by to assist if needed. Prevention: All incoming totes need to be inspected by the warehouse personnel for leaking valves, punctures, or pressure built up inside the tote. If a tote fails this inspection then that tote must be rejected. All totes are inspected before shut down. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Editi on. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. We also have an air operating permit ID under Title V of the Clean Air Act. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Pacific Epoxy Polymers, INC. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analysis is hazard and operability analysis . The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a yearly interval. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Pacific Epoxy Polymers, INC. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Pacific Epoxy Polymers, INC. has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every year and more frequently as needed. Mechanical Integrity Pacific Epoxy Polymers, INC. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Pacific Epoxy Polymers, INC. to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established proc esses are conducted as a regular practice at Pacific Epoxy Polymers, INC.. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Pacific Epoxy Polymers, INC. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Pacific Epoxy Polymers, INC. promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Part icipation Pacific Epoxy Polymers, INC. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Pacific Epoxy Polymers, INC. has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Fiv e-year Accident History Pacific Epoxy Polymers, INC. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Pacific Epoxy Polymers, INC. carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Enclosure of the outside pipe lines, insertion of more fail safe valves, installing liquid level gauges on totes and tanks, installation of a draft blower on the scrubber exhaust to create a positive draft from kettles and vent systems, and adding increased security and security gates at our entrances are some of the major steps we want to take to improve safety at our facility. These changes are being implemented daily and we, at Pacific Epoxy Polymers, Inc., are seeing most of these major steps would be implemented by January 1, 2000. 8. Certification Statement 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. Name: David Stouffer Signature: Title: Assistant Plant Manager Date signed: 6/15/99 |