Taylor Chemical, Inc. - Executive Summary |
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EXECUTIVE SUMMARY This Risk Management Plan (RMP) has been prepared to meet the requirements of the Risk Management Program Rule. As part of complying with the Risk Management Program Rule, Taylor Chemical, Inc. (Taylor) has reviewed and enhanced previously existing accidental release procedures and emergency response policies. A formal Emergency Action Plan has been developed and implemented that includes the following: Emergency Notification and Communication Procedures Fire / Explosion Medical Bomb Threat Severe Weather Conditions and Natural Phenomenon Environmental Chemical Spill / Release Power and /or Equipment Failure Interruption or Failure of Fire Protection Equipment Civil Disturbance Emergency Action Plan Responsibilities Emergency Action Coordinator Site Operating Personnel Fire and Hazard Area Identification Site Plot Plan / Map Emergency Evacuation Exits and Points of Assembly Rescue Procedures Emergency Procedures Electrical Power Failure City Water Failure Hazardous Material Spill Response Decontamination Procedures First Responder Operations Level Spill Containment and Disposal Procedures Public and Private Spill Containment and Disposal Services including CHEMTREC / CHEMNET Fire Bomb Threat Crowd Control Public Disturbance Hurricane, Tornado, Flood, Earthquake, Severe Storms Fire and Hazardous Material Spill Emergency Pre-Plan Cooperative Community Efforts, Drills, Tours (LEPC) Material Safety Data Sheets for Chemical Substances Emergency Procedures and Equipment Life Safety Emergency Equipment, Supplies and Material List (Inventory) Training Emergency Action Plan Incipient Fire Fighting First Responder Operations Level Spill Containment and Disposal There are two substances at the Taylor facility that are regulated by the Chemical Accident Prevention Provisions defined at 40 CFR Part 68. These substances are used in various processes throughout the facility to produce water treatment polymers. Substances that are used by Taylor that are regulated as either toxic substances or flammable substances by 40 CFR Part 68 are as follows: Toxic Substances: Formaldehyde: Formaldehyde is received and stored as a 37 percent solution in water. The maximum amount of 37 percent formaldehyde stored on-site is 77,000 pounds (29,000 pounds pure formaldehyde). Flammable Substances: Dimethylamine: Dimethylamine is received and stored as a 60 percent solution in water. The maximum amount of 60 percent dimethylamine stored on-site is approximately 54,000 pounds (32,000 pounds pure dimethylamine). Worst-case Scenarios: As required by the Risk Management Program Rule, worst case and alternative release scenarios were evaluated and are discussed in this RMP. As required, worst case scenarios are presented in the RMP for one toxic substance and one flammable substance. Alternative scenarios were prepared for each of the toxic substances with worst case endpoints located offsite and for one flammable substance. The endpoint represents the distance at which a released substance must travel before it disperses sufficiently to no longer pose a hazard to the public. For the worst case scenario, EPA has defined a worst-case release as the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to a specified endpoint. For the worst-case analysis, the possible causes of the worst-case release or the probability that such a release might occur are not considered. The release is simp ly assumed to take place and the greatest amount held in a vessel is suddenly released. The results of the worst case scenario analysis were as follows: Toxic Substances: The formaldehyde storage tank was assumed to fail and subsequently produce an instantaneous release of the entire tank contents. The release was assumed to evaporate over a 10-minute time period. The passive mitigation control of the tank dike were considered in limiting the release impacts. The distance to the toxic endpoint was estimated to be less than 0.19 miles. The release rate according to OCA Guidance was calculated to be 0.067 pounds per minute. However, a release rate of 0.2 pounds per minute was entered into the RMP Submit document since this is the lowest value that can be entered into the program. Flammable Substances: The dimethylamine storage tank was assumed to fail and subsequently produce an instantaneous release of the entire tank c ontents that results in a vapor cloud explosion. No passive mitigation controls were considered in limiting the release impacts. The distance to the explosion endpoint was estimated to be less than 0.24 miles. Alternative Release Scenarios: Alternative release scenarios are more realistic scenarios that result in endpoints that affect public receptors. For formaldehyde the release was assumed to occur as a result of the uncoupling or rupture of a transfer hose during unloading operations. For flammable materials, the alternative release scenario assumed that dimethylamine was released as a result of the uncoupling or rupture of a hose during unloading operations. The durations for releasing these materials from a vessel/pipe for the alternative release scenarios were assumed to occur over a 45-second time period since the unloading operations are supervised. With the exception of considering that these transfer operations are monitored by personnel at all times, no other mitigating controls were assumed to limit the releases. The results of the alternative release scenario analysis were as follows: Toxic Substances: Formaldehyde, 37 percent - 0.06 miles Flammable Substance: Dimethylamine - 0.06 miles Prevention Program: To address potential accidental releases, an accidental release prevention program along with chemical specific prevention steps have been developed. The key parts to the program are: Formal Company Risk Management Procedure that includes: Management Systems Responsibilities Risk Management Plan Coordinating Review Team Risk Management Plan Changes and Updating Recordkeeping Requirements Communication and Coordination of Risk Management Information DOT Hazardous Material Training Contractor Performance Selection Process Operating Procedures Emergency Procedures N ew Employee Environmental Health and Safety Orientation Training Program Process Safety Program Auditing Engineering Controls that Include Automatic Level and Interlock Alarms and Shutdowns 24-hour Emergency Communications Additionally, the facility has programs to address the OSHA Process Safety Management (PSM) requirements for the chemicals formaldehyde and dimethylamine, such as: Mechanical Integrity - Preventive Maintenance of Equipment Pre-startup Safety Reviews Management of Change Process Hazard Analysis Incident Investigation Emergency Response Program: The facility also has an emergency response program (ERP) that has been enhanced as part of implementing the Risk Management Program. The ERP has historically been coordinated with the county dispatcher (i.e., 911) and Lackawanna County Emergency Service and Pennsylvania Emergency Management Agency. As part of preparing the RMP, the facility's five year accident history was reviewe d. No accidental releases from covered processes have occurred that resulted in deaths, injuries, or significant property damage on-site or off-site; or resulted in off-site evacuations or sheltering in place. Safety Improvement: Taylor is committed to continuous improvement of safety. Planned changes and policies to promote this improvement include updating and implementing safe work practices such as: confined space entry permits; hot work permits; pipe entry permits; lock-out tag-out procedures; and hazard communication procedures. |