Burlington Industries - Clarksville Facility - Executive Summary |
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Burlington Industries owns and operates a textile manufacturing facility at 899 Burlington Drive in Clarksville, Mecklenburg County, Virginia. This facility is surrounded by local residences, businesses, and the Roanoke River. The Burlington Industries facility employees approximately 1,300 full-time persons from the surrounding community. It is the policy of Burlington Industries to meet all requirements established by applicable safety, health, and environmental regulations. The Burlington Industries Clarksville facility is subject to 40 CFR 68 for propane and chlorine and subject to General Duty requirements of this regulation for sulfur dioxide and anhydrous ammonia. The Burlington Industries Clarskville facility stores propane on-site. The facility maintains three (3) 30,000-gallon and two (2) 18,000-gallon above-ground storage tanks. Propane is used at the facility as a fuel source for some production processes. In addition, the facility uses propane to power lift trucks used at the facility. The Burlington Industries Clarksville facility stores chlorine at its wastewater treatment plant in one ton cylinders. Burlington Industries is required by the DEQ and Health Department to chlorinate (disinfect) all wastewater effluent. The "worst-case release scenario" for propane is the release of the entire contents of the largest storage tank, a 30,000 gallon (125,647 lbs) tank due to rupture. For flammable substances, such as propane, it is assumed that the maximum amount of the substances vaporizes resulting in a vapor cloud explosion. The analysis incorporates a 10 percent yield factor for TNT-equivalency models. The distance to the endpoint is defined as the distance over which a minimum pressure of one (1) pound per square inch (psi) occurs from the pressure wave formed by detonation. No passive mitigation was considered in determining the worst-case impact. The maximum distance to the endpoint was determined using the EPA's RMP Off-Site Consequen ce Analysis Guidance (May 1996) and verified by using the RMP CompTM Program. The "worst-case release scenario" for chlorine is the release of the entire contents of the largest cylinder directly to the atmosphere. For release of 2,000 lbs of chlorine over a 10-minute period, the distance to the toxic endpoint was determined using the EPA's RMP Guidance for Waste Water Treatment Plants (October 1998) and verified by using the RMP CompTM Program. The "alternative release scenario" for propane is assumed to be a instant rupture of the tank truck at 85% capacity or 9,860 lbs. The maximum distance to the flammable endpoint was determined using the EPA's RMP Off-Site Consequence Analysis Guidance (May 1996) and verified by using the RMP CompTM Program. This scenario is based on an assumed wind speed of 3.0 meters per second (6.7 miles/hr), Class D stability, and an air temperature of 77 degrees Fahrenheit (770F) at 50 percent relative humidity (50% RH). Several alternative release sc enarios were identified for propane. The scenario thought to be the most likely to occur, pressure releif valve lifting due to overpressurization/overfilling, did not result in an off-site impact. The "alternative release scenario" for chlorine is assumed to be a release at 35 lb/min. This is a conservative estimate based on a previous incident at the facility. The maximum distance to the toxic endpoint was determined using the EPA's RMP Guidance for Waste Water Treatment Plants (October 1998) and verified by using the RMP CompTM Program. This scenario is based on an assumed wind speed of 3.0 meters per second (6.7 miles/hr), Class D stability, and an air temperature of 77 degrees Fahrenheit (770F) at 50 percent relative humidity (50% RH). The Burlington Industries Clarksville facility has worked to maintain a safe environment for it's employees and the surrounding commuity. There have been no incidents involving propane at the facility. There has been one incident at the fac ility involving chlorine. Facility personnel and local emergency response agencies took immediate action and the incident resulted in no injuries or fatalities to plant or off-site persons. In response to this incident, Burlington Industries reviewed all procedures, maintenance activities, detection systems, and emergency response actions. The facilty up-graded the detection system. Any release occcurring today, should be detected immediately. The facility has established an emergency response program detailing specific actions to be taken in the event of a propane incident with and without fire. These actions are outlined in the Burlington Industries Emergency Procedures Manual and Alert Diagrams. The facility has coordinated emergency response plans with the Clarksville Police and Rescue Squad. |