Franklin Industrial Minerals - Executive Summary |
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General Executive Summary for Franklin Industrial Minerals Kings Mountain, North Carolina 1. Accidental Release Prevention and Emergency Response Policies We at Franklin Industrial Minerals (Franklin) 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 coordinated with Cleveland County LEPC and Emergency Management and Bethlehem Church Road Volunteer Fire Department which provides trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled The facility is a mineral mine. Four min erals are produced at the mine with mica being the primary product. Secondary products include feldspar, kaolin clay and quartz sand. We have two regulated substances present at our facility. These substances are propane and hydrofluoric (HF) acid at a concentration of 70% by weight. The propane is used as a backup fuel for dryers at the site and the hydrofluoric acid is used in floatation of the feldspar. The maximum inventory of propane at our facility is 110,000 lb. The propane is stored in a 30,000 gallon (110,000 pounds max) tank filled to a maximum of 87% capacity. The use of propane as a fuel and the potential for offsite impact places this process in the RMP program 2 prevention program. The maximum inventory of HF of 6,000 gallons is stored in one 6,000 gallon-above-ground tank located at the site. In general the tank is never filled above 4,500 gallons. The weight of HF in 6,000-gallons of 70% solution HF is approximately 43,000 pounds, which exceeds the threshold q uantity of 1,000 pounds in the RMP rule. The facility is not covered by Occupational Safety and Health Administration (OSHA) Process Safety Management and because a potential exists for offsite impacts resulting from the accidental release of HF, the process falls under the RMP Program 2 prevention program. 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 Consequence Analysis Guidance and the model EPA Comp. The following paragraphs provide details of the chosen scenarios. Propane The worst case release scenario submitted for flammable substances as a class involves a catastrophic release from the storage tank in the Propane process. The scenario involves the release of 110,000 lb. of propane from the storage t ank. 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 (ten residences) is obtained corresponding to an endpoint of 1 psi overpressure. Approximately 140 people reside within this radius according to the 1990 Census data. The alternative release scenario submitted involves a release from the propane 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 propane in 10 minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.05 miles. No residences are located within this distance. Hydrofluoric Acid The worst case release for the HF process involves total failure of the 6,000-gallon HF tank releasing 43,000 pounds of HF. A diked area surrounds the HF tank and would contain the liquid HF. The liquid HF would form a vapor cloud. The maximum distance to a toxic endpoint concentration is modeled to be 0.82 miles. Residences are located within this distance with an estimated population of 205 residences with an estimated population of 540 persons based on 1990 Census data. The alternative release scenario involves the overfilling of a 120-gallon day tank. One hundred and twenty-gallons of HF is assumed released over a 20-minute period. The day tank is located within the diked area. The maximum toxic endpoint concentration is modeled to be 0.2 miles. There are approximately 20 persons within a 0.2 mile radius of the HF tank. 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 propane system was designed and constructed in accordance with applicable NFPA-58 Standard. The following sections briefly describe the elements of the release prevention program in place at our stationary source. Process Safety Information Franklin maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with the process. Hazard Review Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. Checklists are used to guide the hazard review. 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 review are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Franklin maintains writ ten operating procedures. These procedures address various modes of operation and are used to train employees and contractors and are used as a reference for actions to take in normal and abnormal operating situations. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Franklin 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. Maintenance Franklin properly maintains each piece of equipment in the covered processes. The maintenance program includes; 1) procedures to guide workers safely in their maintenance tasks, 2) worker training in maintenance procedures, and 3) an inspection and testing program to identify equipment problems before equipment failure occurs. Compliance Audits Franklin conducts audits on a regula r 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. Incident Investigation Franklin 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 reoccurring. All reports are retained for a minimum of 5 years. 5. Five-year Accident History Franklin 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 which has caused offsite impact. 6. Emergency Response Plan Franklin coordinates with the Cleveland County LEPC and Emergency Managem ent Department and Bethlehem Road Volunteer Fire Department to deal with accidental releases of hazardous materials. 7. Planned Changes to Improve Safety Based upon our ongoing review of safety conditions, no imminent changes are planned at this time. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Signature: Title: Date signed: 1 |