BGF INDUSTRIES, ALTAVISTA PLANT - Executive Summary |
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EXECUTIVE SUMMARY Facility Overview: The BGF Altavista facility in Altavista, Virginia is a textile manufacturing operation providing fiberglass and kevlar products. The facility is regulated under RMP due to onsite propane storage being in excess of the 10,000 lbs. flammability RMP applicability threshold in a single process. The facilitys only RMP covered process is the propane storage system which provides fuel for onsite equipment. The covered process consists of 4 tanks with the single largest vessel storing a maximum of 30,000 pounds. Chemical Safety Overview: The facilitys 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 propane in response to the RMP requirements. The management structure and oversight to ensure safety is documented in the facilitys RMP and includes compliance with applicable regulations, codes and standards (US EPA 40 CFR 68 and NFPA 58 guidance for propane). Release Scenarios: Worst-case and alternative release scenario assessments were conducted for the facilitys single largest vessel based on US EPAs Offsite Consequences Analysis guidance. The vapor cloud explosion scenario was considered for both releases and public receptors were determined to be located within the impact zone of both the worst-case and alternative releases. The resulting worst-case and alternative release impact zones were 0.39 miles and 0.26 miles, respectively. NFPA 58 guidance on restricting the maximum propane inventory stored within a vessel to 88% (at (60F) of the vessels rated capacity is followed at the facility to minimize the potential quantity released in an accident scenario. Five Year Accident History: The facility has had no RMP reportable accidents/releases of propane within the five years proceeding RMP submittal. Prevention Program: The facility has implemented a program level 2 prevention program, a required by the RMP rules, in accordance with US EPA, NFPA 58, NPGA, and vendor guidance for propane. These prevention program provisions are specifically intended to minimize the probability and/or consequences of any accidental propane release from the facility and include such measures as a system hazard review, operating and maintenance procedures, training, compliance and auditing, management system and updates, etc. 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 Altavista Fire Department to ensure that they will respond to any accidental release from the propane system. The facility has also established a notification mechanism to ensu re the Fire Department will be properly notified when any response is needed for a propane release. Based on this coordination with the local emergency responders, the facility is not required to implement 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 propane system through active adherence to the appropriate procedures and codes. To ensure that the appropriate changes occur as necessary to maintain/improve safety, ongoing hazard reviews and training, audits, maintenance and investigations ill 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 fa cility has been conducted in accordance with all 40 CFR 68 requirements and the facility has certified RMP compliance. |