CertainTeed, Kansas City Plant - Executive Summary |
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General Executive Summary 1. Accidental Release Prevention and Emergency Response Policies We at CertainTeed, Kansas City Plant 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. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass manufacture of wool fiberglass insulation. We have 2 regulated substances present at our facility. These substances include Propane and Ammonia (aqueous). Propane is used for fuel for forklifts. Ammonia (aqueous) is used as a process ingredient. The maximum inventory of Propane at our facility is 26838.00 lb. while Ammonia (aqueous) is p resent at our facility in a maximum quantity of 20191.50 lb.. 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 offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. Aqua ammonia storage qualifies as a program level 1 process. In the worst case scenario for this process 20192 lb. of Ammonia (conc 20% or greater) is released. The entire storage area is enclosed by a building with a sump and recovery system. These mitigation systems have the effect of limiting the amount of ammonia released in a worst case scenario. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.06 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. This distance is less than the dis tance to the nearest public receptor. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from Propane Storage. In this scenario 26838 lb. of Propane is released. The release quantity has been limited to 88% of the maximum capacity of the source by a system of administrative controls. 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 calculated distance of 0.24 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Propane Storage. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 13419 lb. of Propane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.12 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information CertainTeed, Kansas City Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is review by qualified professional. The studies are undertaken by a team of qualified personnel with expertise in engineer ing and process operations and are revalidated at a regular interval of one year. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 05/18/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, CertainTeed, Kansas City Plant 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. Training CertainTeed, Kansas City Plant 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. Refresher training is provided at least every year and more frequently as needed . Mechanical Integrity CertainTeed, Kansas City Plant 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 CertainTeed, Kansas City Plant to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 05/18/1999. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modificatio n in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at CertainTeed, Kansas City Plant. The most recent review was performed on 11/11/98. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits CertainTeed, Kansas City Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 03/03/1998. 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. Incident Investigation CertainTeed, Kansas City Plant promptly investigates any in cident 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 corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation CertainTeed, Kansas City Plant 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. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance o f the contractor is carried out. CertainTeed, Kansas City Plant 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 emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History CertainTeed, Kansas City Plant has had 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 CertainTeed, Kansas City Plant carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure prop er functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Wyandotte County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 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. Spill prevention projects and training are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by 11/1/99. |