Dan River Inc. - Brookneal Plant - Executive Summary |
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Executive Summary for Dan River Inc. - Brookneal Plant 1. Accidental Release Prevention and Emergency Response Policies We at the Dan River Inc. - Brookneal Plant are strongly committed to associate, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass finishing textile fabrics. We have two (2) regulated substances present at our facility. These substances are chlorine and sulfur dioxide (anhydrous). The chlorine is used for water and wastewater dechlorination while the sulfur dioxide is used for wastewater treatment. The maximum inventory of chlo rine at our facility is 10,000 pounds while sulfur dioxide is present at our facility in a maximum quantity of 8,000 pounds. 3. The Worst Case Release Scenario and the Alternative Release Scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the EPA's Guidance for Wastewater Treatment Facilities Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release of chlorine from the wastewater treatment plant. In this scenario 6000 pounds of chlorine is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated toevaporate over 10 minutes. The released quantity has been limited to 55% due to passive mitigation. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.3 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. The alternative release scenario for chlorine involves a hole in the vapor space of a tank. This scenario involves the release of 180 pounds of chlorine. A 1/4-inch diameter hole has a release rate of 9 pounds per minute. At Class D atmospheric stability and 3 m/s windspeed, the maximun distance of 0.1 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. A similiar alternative release scenario for sulfur dioxide (anhydrous) involves a hole in the vapor space of a tank. This scenario involves the release of 60 pounds of sulfur dioxide. A 1/4-inch diameter hole has a release rate of 4 pounds per minute. At Class D atmospheric stability and 3 m/s windspeed, the maximum distance of 0.1 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. 4. The General Accidental Release Prevention Program and the Chemi cal Speciffic Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR Part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Dan River Inc. - Brookneal Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is What If/Checklist (combined). The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of three years. Any findings related to the hazard analysis are addressed in a timely manner. A PHA/update was conducted on 05/28/1999. Operating Procedures For purposes of safely conducting activities within our covered processes, Dan River Inc. - Brookneal Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, emergency shutdown, emergency operations,normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Dan River Inc. - Brookneal Plant has a comprehensive training program in place to ensure that associates who are operating processes are competent in the operating procedures associated with this process. Refresher training is provided at least every two years and more frequently as needed. Mechanical Integrity Dan River Inc. - Brookneal Plant carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed.. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Dan River Inc. - Brookneal Plant to manage changes in process chemicals, technology, equipment and procedures. The must recent review/revision of maintenance procedures will be performed on 08/25/1999. Process operators, maintenance personnel or any other associate whose job tasks are affected by a modification in process conditions are promptly made aware of and offered trai ning to deal with the modification. Pre-Startup Review Pre-startup safety reviews related to new processes and to modification in established processes will be conducted as a regular practice at the Dan River Inc. - Brookneal Plant. These reviews will be conducted to confrim that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Dan River Inc. - Brookneal Plant will conduct audits on a regular basis to determine wheter the provision set out under both PSM and RMP rules are being implemented. A compliance audit is scheduled for 08/25/1999. These audits will be carried out a least every three years and any corrective action required as a result of the audits will be undertaken in a safe and prompt manner. Incident Investigation Dan River Inc. - Brookneal Plant promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a reg ulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of five years. Associate Participation Dan River Inc. - Brookneal Plant truly believes that process safety management and accident prevention is a team effort. Associates familiar with the processes involved participate in the committee that develops and implements these programs. In addition, our associates have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Dan River Inc. - Brookneal Plant has a strict policy of inf orming the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures of emergency response should an accidental release of a regulated substance occur. 5. Five-Year Accident History Dan River Inc. - Brookneal Plant has had an excellent record of preventing accidental releases over the last five years. Due to stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Dan River Inc. - Brookneal Plant has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Campbell County is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety The recent acquisition of this facility has seen the implementation of various new or modified programs. Some of the steps we want to take to improve safety at our facility includes pre-startup reviews, equipment integrity and updating of training. |