Eveready Products Corporation - Executive Summary |
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General Executive Summary for Chemical, Manufacturing Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Eveready Products Corporation 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 Contract manufacturer of aerosol products. We have 4 regulated substances present at our facility. These substances include Isobutane [Propane, 2- methyl], Methyl ether [Methane, oxybis-], Propane and Difluoroethane [Ethane, 1,1-difluoro-]. Isobutane [Propane, 2-methyl] is used for an aeros ol propellant. Methyl ether [Methane, oxybis-] is used for an aerosol propellant. Propane is used for an aerosol propellant. Difluoroethane [Ethane, 1,1-difluoro-] is used for an aerosol propellant. The maximum inventory of Isobutane [Propane, 2-methyl] that is expected to be present in this facility based on process/operational requirements is 21161.68 lb. while Methyl ether [Methane, oxybis-], Propane and Difluoroethane [Ethane, 1,1-difluoro-] are expected to be present at our facility in quantities of 13546.84 lb., 13427.65 lb. and 11083.82 lb. respectively. 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. The worst case rel ease scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from A75, Tanks 15 and 16. In this scenario 8300 lb. of Flammable Mixture: Isobutane [Propane, 2-methyl], Propane is released. 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 0.16 miles is obtained corresponding to an endpoint of 1 psi overpressure. One alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from A75, Tanks 15 and 16. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 8300 lb. of Flammable Mixture: Isobutane [Propane, 2-methyl], Propane in 10 minutes. The release is also controlled by active mitigation measures that include Fire Water Monitors. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.08 miles. Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from DME/152a, Tanks 11 and 12. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 12000 lb. of Flammable Mixture: Methyl ether [Methane, oxybis-], Difluoroethane [Ethane, 1,1-difluoro-] in 10 minutes. The release is also controlled by active mitigation measures that include Fire Water Monitors. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.07 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. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Eveready Products Corporation 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 HAZOP. 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. The most recent PHA/update was performed on 06/11/1999. Operating Procedures For the purposes of safely conducting activities within ou r covered processes, Eveready Products Corporation 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 Eveready Products Corporation 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 three years and more frequently as needed. Mechanical Integrity Eveready Products Corporation 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 ve nt 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 Eveready Products Corporation to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 06/11/1999. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification 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 Eveready Pr oducts Corporation. The most recent review was performed on 06/11/1999. 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 Eveready Products Corporation 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 06/11/1999. 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 Eveready Products Corporation 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 corrective actions to prevent the release from reoccu rring. All reports are retained for a minimum of 5 years. Employee Participation Eveready Products Corporation 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 analysis 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 of the contractor is carried out. Eveready Products Corporation 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 Eveready Products Corporation 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 Eveready Products Corporation 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 proper 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. Cuyuga County 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. Employee's suggestions, vendor equipment modification, hazard analysis, and re-engineering of the process are some of the major steps we want to take to improve safety at our facility. These changes are continuously being implemented. |