Troy Mills, Inc. - Executive Summary |
|
EXECUTIVE SUMMARY (40 CFR 68.155) The accidental release prevention and emergency response policies at Troy Mills Inc., Troy, New Hampshire: This facility complies with NFPA-58 requirements for LP-Gas storage, and it is our policy to adhere to all applicable federal, state, and local laws. If an emergency were to occur, it is our policy to notify the Southwestern New Hampshire District Fire Mutual Aid System (911 or 603-352-1100). The Mutual Aid Dispatcher then notifies the local fire, police, and emergency response services required to respond to that particular emergency. Facility description and regulated substances handled: Troy Mills Inc. is a manufacturer of non-woven needle punched textile goods for distribution to automotive, filtration, apparel and home furnishings industries internationally. Activities at this facility include administrative/accounting, marketing, manufacturing, R & D, warehousing and distribution functions. Our present maintained maximum in ventory of propane is above the threshold quantity for propane as determined under 40 CFR 68.115, requiring us to comply with 40 CFR 68 - Chemical Accident Prevention Provisions. This facility utilizes propane for rolled goods processing (drying & singeing) as well as heating of warehouse and office space. This system consists of one 30,000 gallon tank (Tank #1), one 15,000 gallon tank (Tank #2), and associated piping, vaporizers, valves, burners and other miscellaneous equipment. The tanks are located on opposite sides of a 19 acre parcel, approximately 750 feet apart. The tanks are interconnected by 2 independent 2 lines with normally closed valving located inside the facility. Per 40 CFR 68.10, Troy Mills Inc. meets RMP Program 2 eligibility requirements. The worst-case and alternative release scenarios: Troy Mills worst-case scenario is a failure of the interconnected storage system with both tanks (one 30,000-gallon and one 15,000-gallon) filled to the greatest co ntrolled amount allowed (88% capacity @ 60 F), resulting in a vapor cloud explosion. The resulting distance to the endpoint extends offsite, and public receptors are within the distance to the endpoint. Our alternative scenario is a break in a 2 vapor line directly connected to Tank #1 (30,000- gallon), leading to a 20-minute release and resulting in a vapor cloud explosion. The resulting distance to the endpoint extends offsite, and public receptors are within the distance to the endpoint. The general accidental release prevention program and chemical-specific prevention steps: This facility complies with EPAs Chemical Accident Prevention rule and all applicable federal, state and local codes and regulations. This facility propane system is designed, installed, and maintained in accordance with NFPA-58 and New Hampshire state law. Five -year accident history: Troy Mills New Hampshire facility has never had an accident involving our propane system that caused death, in jury, property or environmental damage, evacuation, or sheltering in place. The emergency response program: Troy Mills has developed and maintains Troy Mills Contingency Plan and Emergency Procedures. Included in this plan are procedures in the event of an emergency involving our propane system. It is our policy to notify the Southwestern New Hampshire District Fire Mutual Aid System (911 or 603-352-1100) requesting emergency response. The Mutual Aid Dispatcher then notifies the local fire, police, and emergency response services required to respond to that particular emergency. We have discussed this policy with the Troy Fire Department and members of the fire department have inspected our propane system. Planned changes to improve safety: None. |