CCL Custom Manufacturing, Inc. - Executive Summary

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CCL Manufacturing, Inc. owns and operates a facility in Cumberland, Rhode Island which is subject to U.S. EPA regulations governing Accidental Release Prevention Requirements: Risk Management Programs (RMP) under Section 112(r) of the Clean Air Act (40 CFR Part 68).  This Risk Management Plan has been developed in accordance with the requirements specified under 40 CFR Part 68, Subpart G.  The Risk Management Plan certifies that CCL has instituted a Risk Management Program at the Cumberland, Rhode Island facility that is in compliance with U.S. EPA RMP requirements. 
The Risk Management Plan follows the format provided by the RMP Data Elements published by U.S. EPA.  In addition to identifying the applicable corporate policies and risk management systems, including comprehensive accident prevention and emergency response programs, the Risk Management Plan identifies a set of worst case and alternative release scenarios and 
the facility's five-year accidental release history.  The Risk Management Plan also verifies that prevention program and emergency response plans are appropriately designed to minimize risks to workers and the potentially affected public.  RMP Data Elements are included as part of this Risk Management Plan. 
1.1 Corporate Statement 
CCL Industries, Inc. recognizes and believes in the importance of safeguarding both our natural resources and our environmental heritage.  As such, we are committed to our customers, employees, and the various communities in which we operate to protect the health of our environment through the development and maintenance of programs which: 
* comply with federal, state, provincial, and local environmental and occupational health and safety legislation. 
* audit compliance with legislative and company standards, identify long term potential liabilities, and take appropriate action. 
* minimize environmental health and safety risks to our employees and the c 
ommunities in which we operate through the use of safe operating procedures, emergency plans, and employee training. 
* conserve natural resources, minimize the generation and discharge of waste, and ensure that any hazardous waste disposal is handled in a safe and socially responsible manner. 
* integrate the "4R" principles-reduction, reuse, recycling, recovery-wherever possible. 
* support customers and suppliers in the development of alternate products and packaging. 
* support efforts to educate consumers and government regarding the environmental impact of our products. 
* promote responsible legislation concerning our products and our industries. 
* identify and deal appropriately with potential environmental risks and liabilities associated with any acquisition, divestiture or discontinuance of operations. 
1.2 Risk Management System 
CCL's Cumberland facility has developed a management system to oversee the implementation of the Risk Management Program in accordance with th 
e requirements of 40 CFR Part 68, Subpart G.  The management system identifies the following job functions by responsibility level: 
CCL Facility Management: Vice President General Manager 
Risk Management Program Development and Implementation: Divisional Environmental Compliance Manager 
Accident Prevention/Process Safety Management Program:  Site Safety Supervisor 
Off-site Hazards Assessment:  Divisional Environmental Compliance Manager 
Emergency Response:  Site Safety Supervisor 
The EPA Risk Management Regulation identifies three levels of requirements for industrial processes.  Program 1 can be applied to any process which has not had a "significant" release of a regulated substance over the five year period prior to the June 1999 compliance date and for which the worst-case release does not affect "public receptors" (e.g. residences, parks and recreation areas, commercial/industrial facilities, hospitals).  Program 2 
applies to any process that is ineligible for Program 1 and is not subject to Program 3.  Program 3 applies to processes that are subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM).  The CCL Accident Prevention Program elements are adopted directly from the compliance program for the PSM standard, consistent with the Level 3 RMP Program requirements for this CCL facility under 40 CFR Part 68.  Program 3 related information is included in the Data Elements section of the Risk Management Plan. 
2.1 Program 3 Process 
The CCL Custom Manufacturing plant in Cumberland produces various consumer aerosol products for major marketers.  These aerosol products contain various amounts of flammable hydrocarbon propellants to provide the pressure to force the product from the container.  Five flammable chemicals are stored at or above the threshold amounts for regulated substances.  These include isobutane, n-butane, propane, 1,1 difluoroeth 
ane, and dimethyl ether (DME). 
Hydrocarbon propellant is delivered to CCL by railcar or truck, transferred to dedicated pressure tanks located in the tank farm and, when needed, piped through a central manifold to the propellant-changing rooms.  Because of the high volatility and flammability of the propellants, all filling operations are conducted in an isolated, specially designed propellant charging room.  These rooms, the high speed filling equipment, and the auxiliary equipment contained therein are designed according to stringent safety codes to guarantee that explosive concentrations of propellant do not occur.  High volume ventilation, organic vapor detection, ultraviolet spark detection and halon suppression equipment are a few of the standard installations.  Typical rooms contain: welded piping, air-opened/spring-closed remotely and manually operated ball valves, heat exchangers, flow, temperature, and concentration sensors and exhaust air plenums.  Each propellant charging  
room is also equipped with an explosion relief panel.  The atmosphere within each room is constantly removed and directed out one or more exhaust stacks.  The concentration of propellant within each room is continuously monitored at the duct's collection plenum near the floor.  When the concentration within the room is less than 20 percent of the lower explosive limit (LEL), the room is ventilated by at least one and one-half air changes per minute.  When the concentration reaches 20 percent of the LEL, high fan speeds automatically activate to ventilate the room more quickly at more than three air changes per minute to decrease the propellant concentration.  If the percentage of LEL exceeds 40, the production filling operation and associated equipment is automatically shut down and the local fire department is automatically notified. 
Propellant is transferred from the tank farm at its equilibrium pressure at the liquid temperature.  To achieve the significant pressure differential req 
uired to facilitate high-speed, efficient filling, the pressure of the propellant must be raised between 600 and 800 psig.  These pressures are obtained through the use of "pressure booster" pumps, called Wheatley pumps.  At CCL, these pumps are located outside each gassing room.  The propellant is then piped to the rotary filling machines in the gassing room.  A recirculation loop handles excess propellant and can accommodate higher recirculation rates depending on the filling machine's demand.  The recirculated propellant may be water-cooled or steam-heated as necessary. 
2.2 Program 1 Process 
CCL also warehouses up to 3 million aerosol cans in an area that is separate from the Program 3 processes. This process qualifies for Program 1 status under 40CFR Part 68.  With an average amount of 40 grams of propellant per can, the total amount of propellant stored is about 270,000 pounds. According to the RMP regulation, a vapor cloud explosion of the flammable material inside such a vesse 
l is considered the worst-case release in the storage process.  The process is considered Program 1 because, according to Section 68.12(b) of the regulation: no public receptors would be affected within the endpoint distance from a worst-case release (see Section 3.1.2) and no accidents have occurred within the past five years resulting in offsite deaths, injuries, or damage to the environment (see Section 5). RMP Program 1 requires a review of the five-year accident history and evaluation of a worst-case release to verify that public receptors would not be affected, and procedures to notify off-site emergency (e.g. fire department) of the on-site hazards associated with the regulated substances. 
For the purposes of developing and maintaining adequate Risk Management Plans, EPA has defined, in its governing rules and guidance a series of modeling methods and assumptions which are to be used as administrative guides for planning purposes.  In order to standa 
rdize and simplify the many factors that can potentially occur in an accidental release situation, some of these assumptions may not take into account the available preventive measures or mitigation methods that could diminish or even eliminate the implied risks that are suggested by "worst-case" analyses.  For that reason, both the results for the standardized "worst-cases" defined by the EPA methods and an alternative case which are believed by CCL to more realistically represent situations that may possibly, but rarely, occur within the lifetime of the facility are presented.  The sections of the Risk Management Plan which discuss both worst-case and alternative cases, are meant to provide the data necessary to develop and evaluate possible improvements in the overall safety programs of the CCL RMP program. 
3.1 Worst Case 
3.1.1 Program 3 Process 
RMP regulations require that each facility complete a worst-case and an alternative case release scenario. Since all five of the chemica 
ls are flammables, one chemical (propane) can be used to represent the impacts of any of the flammables.  EPA has defined a worst-case release scenario that must be used for propane. This release scenario is evaluated using an EPA program, RMP*Comp, to define the distance to a specified over pressure endpoint. The distance to the endpoint is affected by several factors including molecular weight, volatility and heat of combustion.  
The worst-case release scenario for flammable gases is defined as a release of all the contents of the propane loading tank car (142,800 pounds). The total quantity of the propane is assumed to form a vapor cloud, the entire contents of the cloud are assumed to be within the flammability limits, and the cloud is assumed to explode. For the worst-case analysis, 10 percent of the flammable vapor in the cloud is assumed to participate in the explosion (i.e., the yield factor is 0.10). Consequence algorithms were used to determine the endpoint at an overpressur 
e level of 1 pound per square inch (psi). This results in a relatively short endpoint distance extending off-site and affecting nearby public receptors. 
3.1.2 Program 1 Process 
The largest single vessel in the warehouse storage area is an aerosol can containing up to 200 grams, or 0.44 lb of hydrocarbon propellant.  The worst-case release is defined by the RMP regulation as a vapor cloud explosion of the flammable material inside this vessel and the endpoint is an overpressure of 1 psi. 
For the warehouse storage process the worst-case endpoint distance was calculated using RMP*Comp.  For a release of 0.44 lb of propane, the maximum amount  in a single container, the resulting overpressure endpoint distance associated with a vapor cloud explosion does not extend off-site.  As such, public receptors would not be affected by the worst-case release from the warehouse, as defined by 40 CFR Part 68. 
Alternative Case 
A single alternative release scenario addressing all flammable sub 
stances as a class must be one that is more likely to occur than the worst-case scenario and that reaches an endpoint off site, unless no such scenario exists.  The alternative release scenario is also evaluated to define the distance to the specified endpoint.   
The selected alternative release scenario is a release resulting from damage to a 2-inch relief valve on a propane storage tank. The relief valve is assumed to fail completely causing a vapor release at 172 psig.   Vapor is released out of the valve as an expanding a vertically oriented jet.  ENSR's AIRTOX model was used to estimate the mass of  propane in the jet  that would be present in concentrations exceeding the lower  flammability limit (LFL, 2%).  Due to the dilution of the jet, approximately 13.4 pounds of propane would be above this concentration.  If this quantity were involved in a vapor cloud explosion and the EPA's worst-case modeling assumptions were applied, the endpoint distance would extend just beyond the f 
acility boundary, affecting a small number of public receptors.    
Some processes subject to the Risk Management Regulation are also subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM).  PSM governs the same processes and regulated substances at the site that are subject to 40 CFR Part 68.  CCL has a PSM program at the Cumberland facility that includes the following elements: 
* Employee Participation 
* Process Safety Information 
* Process Hazards Analysis 
* Operating Procedures 
* Training 
* Contractors 
* Pre-Startup Safety Review 
* Mechanical Integrity 
* Hot Work Permit 
* Management of Change 
* Incident Investigation 
* Emergency Planning and Response 
* Compliance Audits 
In conjunction with the current RMP and PSM programs in place at the CCL Cumberland facility, there is a standard management practice that requires immediate internal reporting of unusual 
events, including those in which any abnormal emission of regulated chemicals is observed or suspected.  The incident information is reviewed by supervisory staff and a determination is made as to whether a reportable quantity of any chemical listed as requiring reports to regulatory authorities is involved.  If so, the appropriate authorities are notified. 
During the past 5 years (June 1994 to June 1999), CCL Custom Manufacturing has not had a release of  regulated flammable substances from the Cumberland facility that has caused onsite or offsite injuries, emergency response, offsite evacuations, or damage to property or the environment. 
CCL's Cumberland plant has established an Emergency Action Plan (EAP) to ensure appropriate steps are taken to protect the public health and the environment, as well as the safety of plant employees.  The EAP is designed to address foreseeable emergency situations at the facility and provide appropriate hazard and 
emergency preparedness information to employees, contractors, emergency response personnel, and the community.  Emergency situations can include fire, explosion, chemical release or spill, bomb threats, weather emergencies and other natural emergencies.  CCL has developed procedures to be followed in the event of an emergency and a command structure to evaluate an emergency to determine the appropriate action to be taken to remedy it.  CCL staff has a "first response" capability and are able to administer basic first aid and CPR.  CCL will rely on the Cumberland Fire Department and the LEPC for assistance in controlling emergency releases and extinguish fires. 
CCL is committed through its grass-roots Continuous Improvement process to the expansion and refinement of its safety programs with special emphasis on training.  CCL facilities maintain active safety committees with broad involvement in training, incident investigation, and auditing.  T 
hese efforts are supplemented by a Divisional Auditing Program for general and critical safety.  CCL utilizes external professional resources to validate its internal programs and activities.  CCL also maintains strong contact with local fire and emergency management agencies, participating in mock disaster training exercises.
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