Engineered Polymer Solutions, Inc. - Executive Summary |
|
Engineered Polymer Solutions, Inc. (EPS) personnel take great pride in maintaining a safe operation for the employees, the community, and the environment. The primary focus is to prevent accidental releases before they occur, while providing systems that minimize the size of any release that does occur and contain it in as small as area as possible. 1. Accidental release prevention and emergency response policies: It is EPS policy to operate its plants in a manner that protects its employees, the public, and the environment. It is company policy to adhere to all applicable federal, state and local laws. The EPS Williamsport facility has a detailed practiced Emergency Action Plan that is utilized to respond to any accidental releases. 2. Facility Description and regulated substances handled: This plant primarily manufactures aerosol paint resins and smaller amounts other paint resins. The resins are produced from various materials, including toluene diisocyanate. Peak customer demand for resins may require the plant to use 40,000 pounds in a week. Toluene diisocyanate is delivered by truck in completely sealed cylinders that contain 220 gallons (2,200 pounds). The cylinders are stored in the Tank Buildings at the west end of the plant prior to use in the process. When a cylinder is needed, it is moved from the storage area to the enclosed toluene diisocyanate booth in the central Process Building. A single cylinder is used and consumed at a time. The Resin Manufacturing Process does not contain more than 3,000 pounds of toluene diisocyanate at any time. 3A. Worst-case release scenario: As required by the RMP regulation, the worst case release scenario was calculated by assuming the entire contents of the largest container were released. The EPA worst-case release scenario is a rupture of a toluene diisocyanate storage cylinder (220 gallons) while moving the cylinder to or from the Tank Buildings. This scenario is a very unlikely event due to the des ign of the toluene diisocyanate cylinders that meet Department of Transportation requirements for shipment on highways. According to EPA guidance for calculating the consequence of a toluene diisocyanate release, at a distance more than 69 feet (0.013 miles), the toluene diisocyanate air concentration does not pose a threat to the public. There is a single public receptor (East Rust-Oleum Building) within 69 feet of the path where toluene diisocyanate cylinders are moved. EPS personnel have been in contact with Rust-Oleum regarding RMP and the notification of the Rust-Oleum facility is part of the Emergency Action Plan. The distance is calculated based on EPA guidance tables for dense gases, a 60-minute release time, worst case weather, and urban surrounding. EPS calculated that the release rate would be 0.00739 lb/min (entered as 0.2 in RMP*Submit) from an undiked pool about 35 feet wide and 0.4 inches deep. Because of limitations in the EPA-provided reporting software, the sof tware does not allow entry of data with less than 2 decimal places for distance to endpoint and less than 0.2 lb/min for release rate. 3B. Alternative release scenario: An alternative scenario would be a forklift collision with toluene diisocyanate cylinder in the Tank Buildings. These buildings are designed to contain the contents of any of the large tanks and a toluene diisocyanate spill would be completely contained in the buildings. In addition, the Tank Buildings have a trench that would collect any spill and direct it to a spill containment tank. The consequence of a toluene diisocyanate cylinder rupture in the Tank Buildings would be the same as discussed in the worst-case scenario. However, there are no public receptors with 69 feet of the Tank Buildings. 4. General accidental release prevention program and chemical-specific prevention steps: The EPS Williamsport plant has implemented the OSHA Process Safety Management Standard, which is a systematic method of preventi ng accidental releases and complies with EPAs accident prevention rule. As such, the facility has completed a detailed analysis on the process to ensure the safe use and operation of the applicable equipment. Numerous safeguards are in place and include Operational Procedures, manual and automated control systems, safety interlocks, and other accepted good engineering and industry practices. The facility uses procedural as well as technological systems to ensure safe handling of toluene diisocyanate. The toluene diisocyanate cylinders were designed in accordance with US Department of Transportation regulations. 5. Five-year accident history: The EPS Williamsport plant has never had an accident involving toluene diisocyanate that resulted in injuries, property damage or environmental releases. 6. The emergency response program: In the event of an emergency involving toluene diisocyanate, the EPS personnel will notify the Williamsport Fire Department and rely on their experti se to handle the situation. EPS has provided the fire department with the plant Emergency Action Plan and members of the fire department have inspected the plant. The company has contracted with a qualified emergency response firm to aid in the cleanup of a release. 7. Planned changes to improve safety: EPS has an ongoing and continuing process to update and review the manufacturing process for safety considerations. A toluene diisocyanate bulk storage tank will be installed to store material that is handled currently in cylinders. This project will allow this material to be handled in a completely closed system. Any spill from the toluene diisocyanate tank will be contained by a concrete dike that is located farther from the property line. |