Bridgestone APM - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
At Bridgestone APM's Seat Division, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:
l A description of our facility and use of substances regulated by EPA's RMP regulation
l A summary of results from our assessment of the potential offsite consequences from accidental chemical releases
l An overview of our accidental release prevention programs
l A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule
l An overview of our emergency response program
An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely
affecting our employees, the public, and the environment.
l The certifications that EPA's RMP rule requires us to provide
l The detailed information (called data elements) about our risk management program
STATIONARY SOURCE AND REGULATED SUBSTANCES
Our facility produces polyurethane foam seat pads and backs for the automotive industry using a variety of chemicals and processing operations. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release:
Toluene Diisocyanate (TDI) Our facility has one 10,000 gallon storage tank to handle the TDI. TDI is a main component of the chemical mixture used to formulate the foam seat pads.
Our accidental release prevention programs and our contingency planning efforts help us effec
tively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals.
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
EPA's RMP rule requires that we provide information about the worst-case release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario:
Worst-case Release Scenario(s) - Regulated Toxic Chemicals
Our Worst-case Release Scenario would be a catastrophic failure of the 10,000 gallon storage tank. This would involve the involuntary release of up to 10,000 gallons of TDI being released to the diked area located inside our building.
By using an advanced air modeling program, it was determined that the endpoint distance for a catastrophic failure is less than the distance to the nearest public receptor.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEM
ICAL-SPECIFIC PREVENTION STEPS
We maintain a number of programs to help prevent accidental releases and ensure safe operation. The accident prevention programs in place include:
1. Employees that handle the bulk truck unloading of the TDI receive advanced training on the truck unloading and storage
2. We developed internal checklists that are used for every unloading procedure. These checklists reduce the risk of an
3. The physical placement of the storage tank within a concrete dike located inside the building.
4. The storage tank is equipped with a high level alarm and sight gages to prevent overfilling the tank.
5. Inventory records are kept at the plant and are checked before the truck is unloaded into the tank. This verifies that the
tank can accomodate the truck.
l elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.
FIVE-YEAR ACCIDENT HISTORY
We will keep records for all significant accidental chemical releases that occur at our facility.
The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years:
We have not had a significant accidental chemical spill occur at our facility since the facilty has opened.
In the event that a significant spill does occur, we will conduct a formal incident investigation to identify and correct the root causes of the each event.
EMERGENCY RESPONSE PROGRAM
We maintain an integrated contingency plan, which consolidates all of the various federa
l, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting the workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan.
PLANNED CHANGES TO IMPROVE SAFETY
As there has not been any accidental chemical releases from our facility that has caused an offsite impact, we are not required to plan any changes to our program.
Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental release scenario all processes at our facility is less than the distance to the nearest public receptor:
Within the past five years, the process(es) has (have) had no accidental release that caused offsite impacts provided in the RMP rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent offsite impacts from accidental releases.
In the event of fire, explosion, or a release of a regulated substance from the process(es), entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMPlan. 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.
Title: Manager - Environmental Safety & Health
RMP DATA ELEMENTS
The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows:
l Offsite consequence analysis
l Five-year accident history
l Emergency response program