Air Products and Chemicals, Inc. - Executive Summary |
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1. Accidental release prevention and emergency response policies: Epoxy curing agents are the main product line manufactured at this facility. Formaldehyde and Dimethylamine in the amounts handled by our facility is considered hazardous by the EPA. It is our policy to adhere to all applicable Federal and State rules and regulations. Air Products manages the safety of the regulated processes by means of operating procedures, equipment testing and inspectiuons, safety devices (e.g. alarms, shutdowns, instrumentation, relief devices) inherent in the design of this facilty and other controls and systems designed to prevent accidental releases of hazardous chemicals. Safe work practices and training of our personnel supplement the inherent safe design of the plant. Our emergency response program is based upon OSHA's HAZWOPER regulations. Our emergency response plan includes procedures for the notification of the local fire authority and other resources so that appropriate measures can be taken by local emergency responders to control accidental releases. This document has been prepared in accordance with the EPA's Risk Management Plan regulation (40 CFR, PArt 68). The substances and processes considered during the preparation of this RMP and the scenarios described were selected based on criteria established in the regulation. 2. The stationary source and regulated substances handled: The primary purpose of this facility is to manufacture epoxy curing agents. Epoxy curing agents are used in paints, adhesives, composite materials and civil engineering applications. Amines are the active compound in epoxy curing agents. Amines are reacted with other compounds to modify certain properites to meet customer specifications. The plant manufactures a number of curing agents that use Dimethylamine 60% (DMA-60) and Formaldehyde as a raw material. DMA-60 is delivered by railcar and formaldehyde is delivered by tank truck, both are stored in a double walled underg round storage tank on site. DMA-60 and formaldehyde are combined with other raw materials to produce curing agents. This reaction is irreversible and exothermic. All the Formaldehyde is consumed in the reaction. DMA-60 and formaldehyde are regulated substances that are handled at this facility. They are handled in several different situations. The situations coverd by the regulation are as follows: Toxicity: * Tanker Truck off loading of 45,000 pounds of liquid Formaldehyde at ambient conditions. * Pipe rupture of 410 pounds of liquid Formaldehyde at ambient temperatures. Flammable: * Railcar off loading of 160,000 pounds of liquid Dimethylamine at ambient conditions. * Pipe rupture of 150 pounds of liquid Dimethylamine at ambient temperatures. 3. Worst Case and Alternate Case Release Scenarios (Flammable and Toxics) The "toxic worst-case scenario", as defined by the EPA, is associated with a release of formaldehyde, is the rapid release of 45,000 pounds of formaldehyd e at ambient temperature over a 10 minute period, from the tanker truck in which it is being off loaded. A full tanker truck inventory is assumed to be released, resulting in a vapor cloud. The maximum distance to the EPA defined endpoint for this worst case does not reach public or environmental receptors. There is passive mitigation in place controlling the consequences of the release. Also there are active mitigation in place directed at preventing such a release, but no credit for the active mitigation measures were taken into account in evaluating this worst case scenario. The "toxic alternate-case scenario" as defined by the EPA, is associated with a release of formaldehyde, is the rapid release of 410 pounds of formaldehyde, at ambient temperature over a 10 minute period, from a pipe rupture while charging from the underground storage tank to the kettle. The entire contents of the pipe is assumed to be released, resulting in a vapor cloud. The maximum distance to the EPA defined endpoint for this alternate case does not reach public or environmental receptors. Although, there are active controls in place directed at preventing such a release and controlling the consequences, no credit for active mitigations were taken into account in evaluating this alternate case scenario. The "flammable worst-case scenario", as defined by the EPA, is associated with a release of Dimethylamine, is a vapor cloud explosion (VCE) involving 160,000 pounds of Dimethylamine, at 1psi overpressure, from the railcar in which it is being off loaded. A full railcar inventory is assumed to be released and ignite, resulting in a VCE. The maximum distance to the EPA defined endpoint for this worst case does not reach public or environmental receptors. Although, there are active controls in place directed at preventing such a release and controlling the consequences, no credit for active mitigations were taken into account in evaluating this worst-case scenario. The "flammabl e alternate-case scenario" as defined by the EPA, is associated with a release of Dimethylamine, is the vapor cloud explosion (VCE) involving 150 pounds of Dimethylamine, at 1 psi overpressure, from a pipe rupture while charging from the underground storage tank to the kettle. The entire contents in the pipe is assumed to be released and ignited, resulting in a VCE. The maximum distance to the EPA defined endpoint for this alternate case does not reach public or environmental receptors. Although, there are active controls in place directed at preventing such a release and controlling consequences, no credit for active mitigations were taken into account in evaluating this alternate-case scenario. 4. General accidental release prevention program and specific prevention steps: The facility developed prevention program elements based on the Federal EPA's Accidental Release Prevention Plan, the California Accidental Release Prevention Program (CalARP), and OSHA's Process Safety Ma nagement (PSM) regulation. This facility was designed and constructed to comply with applicable state and industry codes. 5. Five-year accident history: This facility has had no accidents involving or accidental releases of dimethylamine or formaldehyde that resulted in any deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 6. The emergency response program: The facility's emergency response program is based upon OSHA's HAZWOPER standard. At this site, employees are trained to recognize emergencies and initiate emergency response from outside agencies. They have been trained to OSHA's First Responder Awareness Level. The employees receive annual refresher training in thier roles in the emergency plan. Emergency response activities have also been coordinated with the Vernon Fire Department. 7. Planned changes to improve safety: The facility resolves reco mmendations from the PHAs and Incident Investigations, some of which may result in modifications to the plant design and operating procedures. |