Floralife, Inc. - Executive Summary |
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Facility Overview: The Floralife, Inc.,facility is located in Walterboro, South Carolina. The facility manufacturer's phenolic foam and dextrose based flower food. The facility is regulated under RMP due to on-site pentane storage in excess of the RMP applicability threshold. Pentane is used as a process chemical for foam production. Pentane is stored in a storage tank having a capacity of 46,800 pounds. . Chemical Safety Overview: The facility's overall approach and commitment to chemical safety is demonstrated by 1) the existing management, training, procedure and maintenance systems already in place at the facility, and 2) the hazard assessment, prevention program and emergency response provisions implemented specifically for chlorine and propane in response to the RMP requirements. The management structure and oversight to ensure safety is documented in the facility's RMP and includes compliance with applicable regulations, codes and standards (OSHA PSM Standard, US EPA 40 CFR 68 and NFPA guidance for propane). Release Scenario's: Worst-case and alternative release scenario assessments were conducted for the facility's single largest vessel based on US EPA's Offsite Consequence Analysis guidance. The worst-case release scenario is a 1 psi explosion of 46,800 pounds of pentane and the alternate release senario assumes a puncture in a supply line resulting in a release rate of 150 pounds per minute of pentane. There are no public receptors within the impact zone of both the worst-case and alternative releases. The resulting worst-case and alternative release impact zones were 0.3 miles and 0.1 miles, respectively. Five Accident History: The facility has had no RMP reportable accidents/releases of pentane within the five years proceeding RMP submittal. Prevention Program: The facility has implemented a Program Level 3 Prevention Program for pentane, as required by the RMP rule, in accordance with the US EPA guidance. These prevention program pr ovisions are specifically intended to minimize the probability and/or consequence of any accidental pentane release from the facility and include such measures as process hazards analysis, operating procedures, training, contractors, pre-startup safety, mechanical integrity, hot work permit, management of change, incident investigation, emergency planning and response, and compliance audits. The facility prevention program is an ongoing system based on periodic training, incident investigations, audits, procedure revisions, and RMP updates as required to reflect facility change and RMP requirements. Emergency Response Program: The facility has coordinated response with the Colleton County Rural Fire Department and the Local Emergency Planning Committee (LEPC) to ensure that they will respond to any accidential release from the pentane system. The facility has also established a notification mechanism to ensure the fire department will be properly notified when any response is neede d for a pentane release. Based on this coordination with the local emergency responders, the facility is not required to implememt additional RMP emergency response program requirements. Safety Management and Changes: The facility is committed to ensuring its operations are safe and in accordance with all RMP requirements, and has established a senior manager responsible for RMP development, implementation, and compliance. This manager is committed to maintain the safety of the RMP covered pentane system through active adherence to the appropriate procedures and codes. To ensure that the appropiate changes occur as necessary to maintain/improve safety, ongoing hazard reviews, training, audits, maintenance and investigations will be conducted as required by RMP. Updates to the RMP will be completed as necessary in response to these activities. Summary: As documented in this submittal, the RMP for the facility has been completed in accordance with all 40 CFR 68 requirements and t he facility has certified compliance. |