Libbey Glass Inc., City of Industry, CA Plant - Executive Summary |
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EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the Libbey Glass, City of Industry, California, facility management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under 29 CFR 1910.119, OSHA's Process Safety Management (PSM) program. Applicable California regulations include CA Health and Safety Code, Article 2 and 8 CCR 5189 Process Safety Management of Acutely Hazardous Materials. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to Libbey's employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. Libbey's ma nagement is committed to providing the resources necessary to implement this policy. Facility Description The Libbey Glass, City of Industry, California, facility combines raw materials to produce glass tableware. The raw materials used in the processes include various dry ingredients that are melted in a furnace and then pressed or blown into various shapes of ware. Support operations include a propane gas system, limited quantities of hydrogen and acetylene and administrative offices. One chemical is utilized at the facility, in sufficient quantities to be subject to the requirements of 40 CFR Part 68 (RMP) and 29 CFR 1910.119 (PSM). The chemical, propane gas, is used to back up the natural gas fuel to the furnaces and to supply propane fueled forklifts. The propane system is also operated by a third party, Energy United Terminals (EUT) as a distribution outlet for sales to wholesalers and retailers. EUT manages the system through Pacific Energy (PE). PE contracts with Industr ial Specialists, Inc. (ISI) for onsite operations and maintenance. This system includes five (5) 30,000 gallon tanks and one (1) 33,000 gallon tank. A smaller, 1,150 gallon, propane storage tank is also located in another area of the facility. This tank is operated by Mutual Propane and is used solely to fill forklifts at the facility. A skid of hydrogen tanks, totaling about 275 pounds, is also located at the facility. Portable acetylene tanks used for torch cutting are stored in a rack or distributed as needed throughout the facility. Worst-Case and Alternative-Release Scenarios Propane The worst-case release scenario for a propane gas release included a release of all the contents of one of the 33,000 gallon (85% filled) propane tanks and subsequent detonation of the resulting propane vapors (per EPA guidelines). This translates to a release of 120,000 pounds of propane. Other assumptions included in the worst-case assessment are: the propane is a liquefied gas; the liqui d completely vaporizes; the tank is not diked; the release does not take place indoors; the nearfield dispersion environment is characterized as urban; the wind speed is 1.5 meters/sec, and the atmospheric stability is classified as F (stable). The results of the worst-case assessment for propane show that the greatest distance for offsite impact is 0.4 miles. The distance to endpoint is defined as the distance over which a minimum of one (1) pound per square inch (psi) occurs from the pressure wave formed by the detonation of the vapor cloud. A 10 percent yield factor is used for the TNT-equivalent model. Table 3 from the RMP Program Guidance document was utilized to determine the endpoint. Two alternative-release scenarios for the propane system were selected, including a release resulting from a truck pull away and breakage of a propane transfer hose. The longest hose is 25', with an inside diameter of 3". The alternative-release rate was derived from the following equations, which are based on the hose size and the properties of propane. The distance is calculated for an explosion endpoint exceeding 1 psi overpressure. Volume of Hose = p (3 in/2)2 x 1 ft2/144 in2 x 25 ft = 1.227 ft3 Wf = 1.227 ft3 x .504 x 62.37 lb/ft3 = 38.57 lb. of propane Pull-away Explosion D = 17 (0.1 x Wf x HCf/HCTNT)1/3 D = 17 (0.1 x 1.227 x 38.57/2.0246 x 46333/4680)1/3 = 48.4 meters = 158.9 feet where: Wf is the weight of propane in kilograms in the vapor cloud HCf is the heat of combustion of propane from Appendix C of EPA's OCA HCTNT is the heat of combustion of TNT from Appendix C of EPA's OCA D is the distance in meters from the explosion where overpressure exceeds 1 psi Process Piping Breaks An additional alternate release scenario was calculated based on a ten minute process piping release of 7,580 pounds/minute from a 2" diameter pipe. The distance to endpoint for a 1 psi overpressure is 0.3 miles, utilizing Table 4 of EPA's RMP Program Guidance Document. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The City of Industry facility is governed by a set of OSHA, USEPA and California regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public, and to the environment. These regulations include: 7 40 CFR Part 68, Accidental Release Prevention 7 40 CFR Part 112, Spill Prevention, Control and Countermeasure 7 40 CFR Part 264, Hazardous Waste Contingency Plan 7 29 CFR Part 119, Process Safety Management 7 CA Health and Safety Code, Article 2 8 CCR 5189, Process Safety Management of Acutely Hazardous Materials The key concepts in Libbeys' release prevention program are employee participation, appropriate design and maintenance of equipment, use of outside contractors for pr opane process system operation, maintenance and emergency response and appropriate training of all employees. Employee participation in the release prevention program is encouraged and supported by Libbey management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the propane system. Libbey employees are not trained to be members of the facility emergency response team for propane. Libbey policy is to construct all new equipment, systems, and facilities in accordance with applicable building and safety codes. This ensures the appropriate safety and release prevention systems are included from the beginning of each project. Libbey is committed to providing appropriate training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during his or her initial orientation for the facility. In addition, Libbey conducts regularly scheduled safety training for al l employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Five Year Accident History Libbey has not had a release of propane from this facility that has affected the public or the environment. Emergency Response Program Libbey has contract personnel (ISI) trained in emergency response available to the facility 24 hours per day, seven days per week. These personnel receive semiannual training on emergency procedures and response techniques. In addition, the local Certified Unified Program Agency (CUPA) will respond to an offsite emergency. Planned Changes to Improve Safety Libbey, Inc. completes a thorough review of the propane systems each time a design change is implemented. The system is also evaluated each time the PHA is revised. Libbey is committed to using these methods to identify and implement ways to improve the safety of these systems. |