RITE OFF, INC - Executive Summary |
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EXECUTIVE SUMMARY Rite Off, Inc. has displayed a commitment to its employees and to the community of Seaford, Delaware in which it operates. With respect to this commitment for Rite Off's team, practicing safety is a condition of employment. As the current owners recently purchased Rite Off in September of 1998, they have placed safety and wellbeing above all else. Safety, in all aspects of our work is a top priority at Rite Off. The personal safety and health of each Rite Off employee supercedes the operational productivity. Training plays a significant role in our Safety Program. Employees are trained to perform their jobs safely, and how to respond to an emergency evacuation. With respect to the community of Seaford, Delaware, we at Rite Off maintain a good working relationship with the Fire Marshall and the local fire department, as we periodically volunteer to have inspections and training. We choose to work well within the community in order to assure the inhabitants th at our procedures and our plant are safe. The flammable chemicals employed in Rite Off's aerosol filling process include Methyl Ether, Difluoroethane, Isobutane, and Propane. More specifically, A46 is a gas mixture of 85% Propane and 15% of Isobutane used as a propellant. Another propellant used is A70, a 50/50 mixture of Propane and Isobutane. The propellants are stored in a Tank Farm on the plant grounds, piped to an external Gas House, where the aerosol cans are filled by the propellants. Subsequently, the cans are mechanically conveyed into the plant from the Gas House for additional product filling and preparation for packaging and ultimately, shipping. The program 3 worst case release scenario for a flammable material is the release of the entire 46,000 pounds storage tank of the A70 (50/50 mixture of propane and isobutane). The distance to 1 psi overpressure is 0.3 mile. Our Alternative Scenario assumes that simultaneously the internal excess flow valve of one of the ta nks within the Tank Farm malfunctions and the cover of the turbine pump becomes separated from its housing unit while the pump is operating, thus causing a release. The turbine pump is attached to the piping, between the Tank Farm and the Gas House. The leak would be detected and controlled within 10 minutes and could result in a vapor cloud explosion impacting a distance of 0.08 miles. Plant personnel knowledgeable of the site specific equipment and procedures developed this scenario. We will soon install a new automated pressure checking devise, which will reduce the reaction time. A gravel layer, acting as a Passive Mitigating System would limit the spread of any potential combustion. Administrative controls include monthly checks for screw connection integrity and gas leaks. Rite Off has complied with Delaware's Extremely Hazardous Substance Risk Management Act (EHSRMA) and the OSHA Process Safety Management regulation. The major hazards identified include fire, explosion, overpressurization, overfilling, and equipment failure technological systems include a series of control valves within the Tank Farm and Piping systems. The Gas House employs a series of shut off systems and alarms. We maintain a gas sensing unit in the main building, heat sensitive releases, sensor heads, automatic pressure relief panels and doors, explosion proof motors, switches and light fixtures, and remote switching devises. Our prevention program includes PHA, training, and a maintenance program including daily, weekly, and monthly schedules. Before starting daily operations, a start-up inspection of all equipment and gassing units is conducted. We have had no reportable accidents or injuries regarding the handling of these flammable chemicals. We maintain an active working relationship with the Seaford Fire Department, and are included in the written community Emergency Response Plan. As part of our Emergency Response Plan, we conduct periodic emergency response drills , followed by a group feedback on the success of the drill and the behavior of the employees. We invite the local fire department to conduct training exercises. We plan on continued employee training in safety procedures and emergency response, including Spanish language versions. Additional safety changes will be implemented as needed to maintain the Risk Management Plan |