THE P.D. GEORGE COMPANY - Executive Summary |
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The P.D. George Company is one of the world's leaders in the development and manufacture of polymers for electrical and electronic material. These polymers are used as electrical insulation in various household appliances, heavy duty electrical equipment, and for automotive applications. The 21 acre facility has been located in north St. Louis since 1934. It is the policy of The P.D. George Company that its employees, its property, the environment, and the general public be protected from any harm that may occur as a result of its operations. The company's Emergency Response Plan is implemented to comply with the overall P.D. George company policy of providing its workers with a workplace free from recognized hazards. This plan is designed to comply with the policy that all potential hazardous conditions remain within plant boundaries so that these conditions will not present a threat to the health and safety of the general public. It is also P.D. George policy that operations o f the plant be developed so as to avoid adverse effects to the environment of the surrounding area during emergency situations as well as during normal operating periods. The preservation of life is considered to be of prime importance and, because of this, all procedures are carried out in such a manner as to minimize risk to emergency personnel. Rescue and medical activities have priority over all other actions. Of the couple thousand raw materials the facility manages on site, Toluene Diisocyanate (TDI) is the only one that is covered by the Risk Management Plan (RMP) under 112(r)7 of the Clean Air Act. TDI is used on site to manufacture polyurethane wire enamels used primarily by the automotive industry. TDI is a liquid at ambient temperature and freezes at 53 F. TDI is received by tank trucks and is offloaded in a newly diked area to a 12,000 gallon storage tank surrounded by secondary containment where it is stored between 70 - 100 F. TDI is handled in a totally enc losed system and is piped to one of several process vessels where it is reacted with other chemicals to form a polyurethane resin. Once the reaction is complete there is expected to be no free TDI remaining. Our worst-case release scenario was determined not to have an offsite impact, as determined using The Society of Plastics Industry's manual customized for TDI users, based on EPA's OCA Guidance. The release scenario consisted of a storage tank containing 122,400 lbs. of 100% TDI (CAS # 26471-62-5) releasing all of its contents to a diked tank farm. The material was stored at 100 F and released to a diked area capable of containing 179,248 lbs. of TDI. The endpoint distance in this worst case scenario was 162 ft and the nearest public receptor was 225 ft. We have had no accidental releases of TDI in the past five years. Should a release occur, our Emergency Control Group is trained to coordinate activities with our local emergency responders. Our preventive measures incl ude providing safety training to all employees and performing regular drills, exercises, and routine process evaluations. Changes we have made that have improved the safe handling of TDI include a no sampling policy, using a Micro-motion level indicator on the storage tank, and installing a containment area for offloading tank trucks. |