Engineered Polymer Solutions, Inc. - Executive Summary |
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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 Marengo 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 water-based latex resins for use in household paint. Vinyl acetate (VA) is used in the manufacture of these latex resins. Peak customer demand for latex resins may require the plant to use 12,000 gallons per day. The plant can store up to 24,000 gallons of VA in an insulated closed stainless steel tank. The tank is located in an outside tank farm that is surrounded by a 3-foot-high concrete dike. The tank farm dike is capable of containing more than the entire contents of the VA tank. 3. 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 the release of the entire contents of the VA storage tank into the diked tank farm. This scenario is a very unlikely event due to the design and maintenance of the storage tank. According to EPA guidance for calculating the consequence of a VA release, at a distance of 0.7 miles, the VA air concentration does not pose a threat to the public The distance is calculated based on EPA guidance tables for dense gases, a 60-minute rele ase time, worst case weather, and urban surrounding. EPS personnel calculated that the release rate would be 109.3 lb/min from a diked area of 3,000 square feet (46 feet by 65 feet). 3B. Alternative release scenario: An alternative scenario would be a hose rupture during unloading of a VA tanker in the Tanker Building. This building is designed to contain the contents of an entire 6,000-gallon tanker (40,000 pounds). Unloading operations are monitored at all times by a truck driver or operator. According the EPA computer program, the VA air concentration would be dispersed within 500 feet (0.1 miles) of the tanker building. There are no public receptors with 0.1 miles of the Tanker Building. The distance is calculated based on EPA computer program for dense gases, a 60-minute release time, worst case weather, and urban surrounding. The hose rupture would produce a hole of 7 square inches that would be 72 inches below the top of the liquid level. The program calculated that the release rate would be 15.6 lb/min from the building floor of 5,000 square feet (50 feet by 100 feet). 4. General accidental release prevention program and chemical-specific prevention steps: The Marengo Facility has implemented the OSHA Process Safety Management Standard, which is a systematic method of preventing 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 VA. The tank was designed and built in accordance with sound and current engineering standards, local building codes, and state law. 5. Five-year accident history: The EPS Marengo plant ha s never had an accident involving VA that resulted in injuries, property damage or environmental releases. 6. The emergency response program: In the event of an emergency involving vinyl acetate, the EPS personnel will notify the Marengo Fire Department and rely on their expertise 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 our manufacturing process for safety considerations. |