Church & Dwight Company Inc. - Executive Summary |
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EXECUTIVE SUMMARY Church & Dwight Company Inc. manufactures consumer products at our plant in Lakewood. We have a strong commitment to operate our facility in a safe and responsible manner. Difluoroethane is used at our facility as a propellant in our aerosol consumer products. The difluoroethane is contained in a closed loop system; it is designed to remain inside the piping, vessels, and filling area in our facility. A. Describe the Accident Release Prevention and Emergency Policies Church & Dwight Company Inc. takes many precautions to prevent or minimize accidental releases of difluoroethane from the aerosol filling system. These precautions include safety controls (alarms, detectors, and automatic shutdown devices) which are designed to identify and prevent potentially unsafe conditions like propellant leaks. We also have a preventive maintenance program designed to maintain the on-going integrity of the systems, a training program designed to ensure that the systems ar e operated by qualified personnel, and to respond quickly to system upsets. The Technical Manager is responsible for the management of these difluoroethane safety programs. B. Stationary Source and Regulated Substances Handled The facility operates an aerosol filling system with an difluoroethane inventory of approximately 143,000 pounds. Difluoroethane is the only substance covered by the Accidental Release Prevention Regulations handled at the Lakewood plant. C. Summary of Worst-Case and Alternative Release Scenarios EPA requires us to define the worst case release scenario from the Lakewood plant as the release of all the difluoroethane from the largest vessel on site. At our Lakewood plant, this would be 53,700 pounds of difluoroethane due to the failure of a storage tank. The 53,700 pounds represents the maximum amount of difluoroethane that would be contained in the tank at any time. EPA also requires us to assume that the weather conditions are such that there is almo st no wind and no mixing in the atmosphere. The alternative release scenario at the Lakewood plant would involve the release of 5,506 pounds of difluoroethane due to the rupture of a 2" line on the tank. Again, EPA required us to estimate the impacts of this release under low wind and stable weather conditions. Also, excess flow valves on in place on all storage tanks. Both of these releases are unlikely for many reasons. Our equipment and system were designed using industry standards for an aerosol filling system. We have taken precautions to protect our equipment from obvious threats, like vehicular traffic. We have a preventive maintenance program to maintain the on-going integrity of the aerosol filling system equipment. Training programs are in place to ensure that qualified personnel operate the systems, and our emergency response procedures allow us to respond quickly in the event of an accident. And lastly, the weather conditions used in estimating the extent of the releases are uncommon. D. Description of the Accidental Release Prevention Program The facility has an accident release prevention program that complies with Occupational Safety and Health Act's Process Safety Management Standard and EPA's Risk Management Program Regulation. The prevention program consists of the following elements: - Employee Participation Program - Process Safety Information - Process Hazard Analysis - Operating Procedures - Training Program - Contractor Safety Program - Pre-Startup Safety Review Procedures - Mechanical Integrity Program - Hot Work Permit Procedures - Management of Change Procedures - Incident Investigation Procedures - Compliance Audit Procedures E. Five-Year Accident History There have been no difluoroethane-related accidents at the Lakewood plant in the past five years. F. Description of the Emergency Response Program An emergency response program has been implemented at the Lakewood plant. This program contains procedures describing how the facility will respond to difluoroethane spills and other emergencies, including evacuation procedures. G. Planned Changes to Improve Safety Church & Dwight Company Inc. is committed to operating our aerosol filling system in a safe and responsible manner. We are continually evaluating our equipment and procedures to meet this objective. Planned improvements include the installation of a propellant recovery system. |