Genpak, LLC - Executive Summary
General Executive Summary for Genpak, LLC |
Charlotte, North Carolina
1. Accidental Release Prevention and Emergency Response Policies
We at Genpak, LLC are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, we are completely coordinated with Charlotte Fire Department which provides highly trained emergency response personnel to control and mitigate the effects of the release.
2. The Stationary Source and the Regulated Substances Handled
The facility manufactures disposable food trays. We have one regulated substance present at our facility. This substance is n-butane. N-Butane i
s actually a mixture of n-butane (95%) and isobutane (5%). In this document, the mixture is referred to as n-butane. The regulated substance at our facility, n-butane, is used for adding fluff in the making of polystyrene food trays and containers.
The maximum inventory of n-butane at our facility is 110,000 lb. The n-butane is stored in a 30,000 gallon (110,000 pounds max) tank filled to a maximum of 87% capacity and in a 23,000 gallon (84,000 lbs max) railcar. These are not connected except during refilling of the storage tank. The railcar is only present on site when the storage tank requires refilling. Therefore, 110,000 lbs is the maximum inventory.
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario
To perform the required off-site consequence analysis for our facility, we have used equations from Appendix D of the EPA's Offsite Consequenc
e Analysis Guidance and the model EPA Comp. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for flammable substances as a class involves a catastrophic release from the storage tank in the n-butane process. The scenario involves the release of 110,000 lb. of n-butane from the storage tank. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of 0.4 miles is obtained corresponding to an endpoint of 1 psi overpressure.
The alternative release scenario submitted involves a release from the n-butane distribution line due to a break in the distribution hose during filling of the tank. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 1,000 lb. of n-butane
in 10 minutes. Under neutral weather c
onditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.05 miles.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This n-butane system was designed and constructed in accordance with NFPA-58 Standard. The n-butane process at our facility is subject to the OSHA PSM standard under 29 CFR 1910.119. The following sections briefly describe the elements of the release prevention program in place at our stationary source.
Process Safety Information
Genpak, LLC maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with the process.
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled eff
iciently. The methodology used to carry out these analyses is a what if analyses. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner.
For the purposes of safely conducting activities within our covered processes, Genpak, LLC maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.
Genpak, LLC has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Ref
resher training is provided at least every year and more frequently as needed.
Genpak, LLC carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at Genpak, LLC to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware o
f and offered training to deal with the modification.
Pre-start up safety reviews related to new processes and to modifications in the established process are conducted as a regular practice at Genpak, LLC. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Genpak, LLC conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
Genpak, LLC promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any correct
ive actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.
Genpak, LLC truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.
On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Genpak, LLC has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergenc
y response should an accidental release of a regulated substance occur.
5. Five-year Accident History
Genpak, LLC has an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period.
6. Emergency Response Plan
Genpak, LLC coordinates with the Charlotte-Mecklenburg LEPC and Charlotte Fire Department to deal with accidental releases of hazardous materials.
7. Planned Changes to Improve Safety
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Replacement of pressure alarms in pellet hoppers, loading procedure modification, and replacement of locking controls of the tank are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by _June 21, 1999.
8. Certification Statement
The undersigned certifies that to th
e best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete.