Pierce & Stevens Seabrook C&A Operations - Executive Summary |
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The Seabrook Polyurethane Business Unit (Seabrook Facility) of Pierce & Stevens Corp., a Division of Sovereign Specialty Chemicals Corp., uses toluene diisocyanate (TDI) which is considered hazardous by the EPA. The same properties that make TDI valuable as a reactant at our facility also makes it necessary to observe certain safety precautions in handling TDI to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our coworkers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable federal and state rules and regulations. Safety depends upon the manner in which we handle TDI combined with (1) safety devices inherent in the design of this facility, (2) the safe handling procedures that we use, and (3) the training of our personnel. The primary purpose of the Seabrook facility is to produce polyurethane coatings and adhesives, which are sold to other Pierce & Stevens facilities, distributor s and manufacturers to be used in a variety of applications ranging from floor coatings to medical devices. TDI is one of the reactants used in the manufacture of these products. TDI is received by tank truck and stored in an indoor storage tank. The TDI is pumped to vessels where the TDI is mixed with other reactants, solvents and additives to form the finished coating or adhesive. The final product is then pumped into drums or pails for shipment to our customers. Access to the site is restricted to authorized facility employees, management personnel and contractors. TDI is the only substance handled at this facility that is regulated by EPA's risk management program (RMP) rule. The maximum amount of TDI that can be stored in the storage tank is 85000 pounds, but administrative controls including written procedures and electronic level devices, are in place to limit the maximum amount of TDI stored in the tank to 78,000 pounds. This limit is in place to prevent overfilling and allow for expansion and contraction of the liquid in the tank. Failure of the TDI storage tank when filled to the maximum inventory would release 78,000 pounds of TDI. The storage room is maintained at 80 0F, but during summer hot spells, the room temperature can rise to 100 0F. To minimize the environmental effect of a massive failure of the TDI tank, secondary containment is in place that will contain the total contents of the TDI tank and prevent it from seeping into the ground. The surface area of this containment is 2600 square feet. Because a release at a higher temperature will result in a greater endpoint distance, we assumed the release to be at 100 0F. It is also assumed that the entire contents of the tank is released as a liquid, forms a 2600 square foot pool and evaporates to form a toxic cloud, which disperses downwind. Using the techniques presented in EPA's RMP Offsite Consequence Analysis Guidance to determine the release rate and using a refined model "GAUSSI AN PLUME", the distance to the endpoint concentration of 0.007 mg/L is 130 feet. The storage tank and containment area is over 240 feet from our property line in any direction, therefore no toxic concentration of TDI will leave our property. The Seabrook facility has a Storm Water Pollution Prevention Program and Preparedness, Prevention & Spill Prevention Response Contingency Plans. These plans are based upon a number of requirements regulated by both OSHA and EPA. The plans emphasize engineering controls where practical and details procedures to follow should a release occur and training requirements for those employees involved. There have been no accidental releases of TDI at the Seabrook facility in the past five years. Our emergency response program is based upon the requirements in OSHA's Hazardous Waste and Emergency Operations (HAZWOPER) regulation (29 CFR 1910.120). The Seabrook Facility's emergency response plan calls for notification of the local fire department and any potential neighbors. Capital improvements have been approved for the Seabrook facility to provide better tanker off-loading facilities and to improve even further the containment of the TDI storage tank. Construction of a containment area with in the tank storage building will significantly reduce the distance of the toxic concentration. |