Continental General Tire, Inc - Executive Summary |
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Accidental Release Prevention and Emergency Response Policy The Continental General Tire, Inc. - Aldora Plant (General Tire) is committed to providing a safe and healthy workplace for all employees while preserving the environment and actively participating as a responsible corporate citizen in the community. As such, General Tire complies with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) and all other applicable federal, state, and local laws. General Tire also conforms with the NFPA-58 requirements for LP-Gas storage. As part of General Tires Emergency Response Program, General Tire has coordinated emergency response efforts with the Lamar County Fire Department. Stationary Source Description and Regulated Substances General Tire is located at 160 Aldora Street in Barnesville, Georgia. The geographical coordinates of the facility are 300 03 12 latitude and 840 10 31 longitude. The facility is dedicated exclusively to the conversion of polyester, nylon, aramid and other types of synthetic yarns into tire cord fabric, and it is listed under the North American Industrial Classification System (NAICS) Code of 314992 (formerly Standard Industrial Classification (SIC) code 2296). Delta Environmental Consultants, Inc. (Delta) evaluated the General Tire facility for the applicability of 40 CFR 68. Based upon the evaluation, Delta determined that the only regulated process at General Tire was the Propane system. In addition, the Propane system was determined to be subject to the requirements for a Program 2 level Prevention program. The Propane system at General Tire consists of the following interconnected equipment: seven (7) 30,000-gal tanks, a propane tank loading station, propane vaporizer and surge tank and associated piping. General Tire uses the vaporized propane as a backup fuel for several process ovens, three chillers, and the facilitys boiler. Propane is also used to power forklifts and various sweepers throughout the plant. Worst-Case Release Scenario As required by 40 CFR 68 Subpart B, General Tire contracted the services of Delta to evaluate a worst-case release scenario for propane using the parameters specified by the EPA. General Tires worst-case release scenario is the rupture of the largest single tank (30,000 gallons) over a 10-minute period when filled to 88% capacity. Using the EPAs RMP*Comp program, the maximum distance to the overpressure endpoint extends offsite and includes public receptors. Alternative Release Scenario A more realistic release scenario (alternative case) was developed for propane by Delta for General Tire considering system design features and facility operating history. The most likely alternative release identified for the facility was the release of propane from a transfer hose due to sudden hose uncoupling resulting from a tank truck pull away. The hose used in the release calculation is 25 feet in length and three (3) inches in diameter. The amou nt of propane released is limited to the mass of propane in the hose since the active mitigation devices are assumed to work as designed. General Tire has system emergency flow cutoff and check valves in place. Using the equations provided in EPAs document, Risk Management Program Guidance for Propane Users and Small Retailers (Part 68)), the maximum distance to the overpressure endpoint was determined to be 0.027 miles, or 143 feet. Accidental Release Prevention Program The Propane system is designed and constructed in accordance with NFPA 58 to prevent and mitigate accidental releases of propane. General Tire has implemented several precautionary measures such as process/equipment controls, standard operating procedures, preventative maintenance programs, as well as employee training and audit programs to safeguard employees, the surrounding community, and the environment. Five -Year Accident History Over the last five years, General Tire has not experienced an off-site rele ase of propane causing any on-site death, injury or significant property damage, or known off-site death, injury, property damage, environmental damage, evacuations or sheltering in place. Emergency Response Program General Tire employees will not respond to an accidental release of propane other than those considered as incidental releases. General Tire has coordinated response activities with the Lamar County Fire Department and has the appropriate mechanisms in place to notify emergency responders when there is a need for a response. Continuous Efforts to Improve Safety General Tires continuous efforts to improve the performance of its safety systems will involve maintaining a well coordinated Risk Management Program. General Tire performs regular inspections and maintenance activities to ensure the continued safety of its operations. |