Foam Materials Inc. - Executive Summary |
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1. Accidental Release Prevention and Emergency Response Policies "All employees of Foam Materials Inc. are provided the following policy statement: It is the policy of Foam Materials Inc. to comply with all Environmental, Health and Safety regulations and requirements. Upon identifying a circumstance which could lead to a violation of a regulation or requirement established to protect human health, safety, and/or the environment, the person (or persons) identifying the circumstance shall take immediate corrective action, if such action is reasonably within their authority and ability to perform. Should immediate correction not be performed, the person (or persons) identifying the circumstance shall immediately inform their supervisor, so that appropriate corrective actions can be taken. Failure to comply with this policy may result in termination of employment." 2. Stationary Source and Regulated Substances Handled Foam Materials Inc. manufactures packaging foam and pellets. Pellets are expanded using steam heat to produce packaging peanuts. Iso-butane is used to manufacture packaging foam. Iso-pentane or an iso-butane / iso-pentane blend is used to manufacture packaging pellets. The maximum amount of iso-butane onsite is 35,000 pounds. The maximum amount of iso-pentane onsite is 22,000 pounds. 3. Worst-Case Release Scenario(s) and Alternative Release Scenario(s), including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario The Environmental Protection Agency defines the worst-case release as the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to an endpoint as defined by 40 CFR 68.22. The largest storage tank at Foam Materials Inc. is the butane tank. The butane tank contents are limited to 85 percent capacity by fire protection requirements. At the time this plan was developed, the Environmental Protection Agency required that the worst-case release be modeled assuming that 10 percent of the largest tank contents is dispersed into the atmosphere at an ideal explosive concentration and ignited (The Environmental Protection Agency was in the process of modifying this requirement at the time Foam Material Inc.'s Risk Management Plan was developed. The effective date for the Environmental Protection Agency's modification was after plan development and therefor could not be included in the plan.). The Environmental Protection Agency also required that a model be used to calculate the distance to a 0.1 pound per square inch overpressure (this is considered the worst-case endpoint). Using the National Oceanic and Atmospheric Administration and Environmental Protection Agency RMP*CompTM Version 1.06 model the worst-case release endpoint was calculated to be 0.3 miles. The Environmental Protection Agency also requires that alternative release scenarios be evaluated. Required alternative release sc enarios evaluated included: 7 Transfer Hose Releases, 7 Process Piping Releases, 7 Process Vessel or Pump Releases, 7 Vessel Overfilling Releases, and 7 Shipping Container Releases. After evaluating the required alternative scenarios, only one scenario was identified that meets the Environmental Protection Agency reporting criteria, and therefore can be included in this report. The reportable alternative scenario results from a delivery truck pull away where the driver forgets to disconnect the transfer hose. The pull away causes failure of the 2-inch diameter, 40 feet long, transfer hose. The excess flow valves and/or isolation valves are considered to work, limiting the release to the contents of the hose. The resulting unconfined vapor is considered to explode (just as in the worst-case scenario assumptions). Using the Environmental Protection Agency's Risk Management Program Guidance for Propane Storage Facilities (40 CFR Part 68), the distance to endpoint was calculated to be 140 feet (As previously discussed, the Environmental Protection Agency was in the process of modifying its requirements. While this modification could not be included in this report.). This release would have the possibility of exhibiting a 1 pound per square inch overpressure onto State Road 1552, which is located on Foam Materials Inc.'s property. Applying the required method, which is undergoing change, this release may also effect North General Boulevard and the office parking lot next to the facility. 4. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps Foam Materials Inc. has developed and implemented a Process Safety Management Plan and Risk Management Program. Foam Materials Inc. performs periodic Process Hazards Analyses and routine safety inspections (commonly weekly). The purpose of the plan, program, analyses and inspections are to ensure the safe operation and maintenance of the butane tank, pentane tank and the associated pro cesses. 5. Five Year Accident History There have been no accidental releases of iso-butane or iso-pentane since the facility began operations in 1993. 6. Emergency Response Program Foam Materials Inc. maintains Emergency Action and Fire Prevention Plans. The primary purposes of these plans are to prevent circumstances which could lead to the need for an emergency response and to ensure employee safety. In the event of an accidental release, Foam Materials Inc. has and continues to work with the City of Lincolnton Fire Department to ensure public safety. Copies of the Emergency Acton and Fire Prevention Plans, and Risk Management Program have been provided to the City of Lincolnton Fire Department. The City of Lincolnton Fire Department also performs periodic inspections of the butane and pentane tanks to supplement Foam Materials Inc.'s routine inspections. In the event of an accidental release, the City of Lincolnton Fire Department will act as the primary emergency respons e agency. 7. Planned Changes to Improve Safety No specific changes are planned to the regulated process. Foam Materials Inc. plans to perform or cooperatively participate in the following safety reviews: 7 Self performed routine inspections of the butane and pentane tanks, 7 Self performed periodic Process Hazards Analyses, 7 Self performed periodic Process Safety Management Plan audits, 7 Self performed periodic Risk Management Program reviews, 7 Insurance carrier inspections, 7 City of Lincolnton Fire Department inspections, 7 Occupational Health and Safety Administration Consultative Services inspections, and 7 North Carolina, Division of Air Quality inspections. In the event changes are identified through these inspections and/or safety reviews that would improve safety, Foam Materials Inc. plans to implement such changes. |