Waterbury Companies, Inc. - Executive Summary |
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28057 LDEQ Facility ID Number 1. ACCIDENT RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: Waterbury Companies understands that accidental release prevention and emergency response are two most important aspects of a safety program. It is our company policy to comply with all federal, state, and local environmental health and safety codes and regulations. Through written programs, policies for accident release prevention and emergency response have been established, and employees trained in corresponding aspects. In addition to written procedures, all process equipment and safety devices are required to be maintained in proper working order and inspected regularly. In 1998, Waterbury increased its commitment to protecting the safety of all employees and the surrounding community by hiring an Environmental Health & Safety (EHS) Specialist. This employee maintains all environmental and occupational safety programs, and coordinated emergency response activities with the local c ommunity. 2. THE FACILITY AND THE REGULATED SUBSTANCES HANDLED: Waterbury Companies, Inc. of Independence, LA is a small industrial facility where fragrance and pesticide formulations are packaged typically in aerosol cans for commercial users. There are two processes that are covered under the Risk Management Plan: aerosol production and aerosol warehouse storage. Both of these processes involve liquefied petroleum gases (LPG) which are used to pressurize aerosol products. The regulated substances handled in the aerosol production process are stored in 5-bulk pressure vessels of various volumes. The regulated substances are difluoroethane (a flammable gas) and four flammable gas mixtures (compromised primarily of liquefied petroleum gasses). All of the tanks are located in one area at the facility that is protected by a deluge system and combustible gas detection sensor. The propellants are combined with solvents and other chemicals to produce the finished product in an aeros ol can. All production areas are sprinklered, and the facility possesses a fire pump that will supply the appropriate volume of water. After cans are filled, they are stored in a separate aerosol warehouse which is considered another process under these regulations. Finished products, which are flammable mixtures of liquids and regulated flammable gases, vary in size from 2-ounces to 30-ounces. The aerosol warehouse is equipped with a sprinkler system which is supplied by the fire pump mentioned above. There is also a fire wall on the side of the warehouse facing Calhoun Street. 3. THE WORST CASE RELEASE SCENARIO AND THE ALTERNATIVE RELEASE SCENARIO: The worst case scenario at this facility involves the failure of the largest pressure vessel and the entire contents are released. As a company safety policy, these tanks are never filled to capacity (as required in NFPA 58), which has been taken into account in the Off-site Consequence Analysis. Of this volume, 10% is assumed t o participate in a vapor cloud explosion. This worst case scenario has off-site consequences that affect the surrounding area. The alternative scenario, which is more probable than a worst case incident, involves the failure of LPG process tubing entering the can gassing house. This failure would cause a substantial leak in a 30-foot length of 1 1/2 steel piping or tubing. The excess flow valve would terminate the release at the pressure vessel, and combustible gas monitoring sensors would detect the vapors sounding an alarm for evacuation. The scenario assumes the unconfined gas remaining from the leak would travel to the lower explosive limit (LEL) and find an ignition source. This would result in a vapor cloud fire that would have the potential to affect the population outside the gates of the facility. Once the cloud would be ignited, the tank farm deluge system would activate to extinguish any resulting flames. 4. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE SPECIFIC PREVENTION STEPS: This facility complies with all federal, state, and industry regulations and standards relating to chemical release prevention. These include the Occupational Safety and Health Administration's Process Safety Management program and the Louisiana Department of Environmental Quality's Chemical Accident Prevention program. These two laws require hazard analyses, maintenance procedures, and operating procedures with the purpose of preventing chemical incidents from occurring. Waterbury Companies has also designed and operated this facility based on several National Fire Protection Association (NFPA) standards for fire prevention safety. These standards include NFPA 30 "Flammable and Combustible Liquids Code", NFPA 58 "Standard for the Storage and Handling of Liquefied Petroleum Gases", NFPA 30B "Code for the Manufacture and Storage of Aerosol Products". 5. FIVE-YEAR ACCIDENT HISTORY: There have been no reportable accidents at this facility in the past fi ve-years. 6. THE EMERGENCY RESPONSE PROGRAM: Waterbury's Emergency Response Program has been written based on the National Response Team's Integrated Contingency Plan Guidance. This plan incorporates the different emergency planning guidelines required by the Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), and Louisiana Department of Environmental Quality (LA DEQ). By combining the requirements of each regulation, Waterbury Companies has enhanced the speed and efficiency of its emergency response, which in turn improved the safety of its employees and the surrounding community. This contingency plan includes preliminary assessments of hazardous material incidents, response procedures, and internal, federal & state, and local community notifications. Employees are trained in response procedures and participate in periodic evacuation drills. In addition, this plan has been discussed with the Independence Fire Department, who would be th e first responders to any incident at this facility. 7. PLANNED CHANGES TO IMPROVE SAFETY: Waterbury Companies is currently exploring the option of building another aerosol warehouse in 1999 which will be designed according to NFPA 30B 1998. |