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 City of Commerce plant 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 and solvent-based alkyd resins for use in household paint. Vinyl acetate (VA) is used in the manufacture of these latex resins. Pe ak customer demand for latex resins may require the plant to use 6,000 gallons of VA per day. The plant can store up to 15,000 gallons (115,000 pounds) of VA in an insulated closed stainless steel tank. The tank is located in an outside concrete 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. Steel piping connects the storage tank to the process area within the Latex Process Building. 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 the rupture of the VA storage tank and release of the entire contents into the diked tank farm. This scenario is a very unlikely event due to the design of the storage tank. According to EPA guidance for calculating the consequence of a VA release, at a distance of 0.4 mile s, the VA air concentration does not pose a threat to the public. There are public receptors within 0.4 miles of the EPS tank farm. 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 45.4 lb/min from a diked area of 1248 square feet. 3B. Alternative release scenario: An alternative scenario would be a release of 660 pounds of VA from the reactor vent line due to an uncontrolled reaction. The volatilization rate for this release was calculated to be 360 lb/min, taking 1.6 minutes to release 660 pounds. According to EPA guidance for calculating the consequence of a VA release (dense gas, 10-minute release time, alternative case meteorology and urban dispersion), at a distance of 0.3 miles, the VA air concentration does not pose a threat to the public 4. General accidental release prevention program and chemical-specific prevention steps: The E PS Commerce plant 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, steel storage tanks, welded piping to reduce potential leaks and weak points, seal-less pumps that eliminate potential leaks, plant operators are trained to shut down the process at the first sign of trouble, 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 and associated equipment were designed and built in accordance with sound and current engineering standards, local building codes including earthquake resistance, and st ate law. 5. Five-year accident history: The EPS Commerce plant has 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 Los Angeles County 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 the manufacturing process for safety considerations. Another latex resin reactor will be added at the end of 1999. As part of this project, computerized controls will be installed for both reactors and a small control room will be added. |