Intertrade Holdings, Inc. - Executive Summary |
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Sulfur dioxide, sulfur trioxide, and oleum are stored and used on site by Intertrade at the Copperhill, TN facility in quantities that exceed the threshold quantities as defined by the Risk Management Program regulations. Intertrade has diligently developed and implemented a comprehensive Risk Management Program, assessing the hazards associated with the process, as well as implementing procedures which minimize the the probability and severity of a release. In the past five years there have been two minor releases, one involving oleum, and the other involving sulfur dioxide. Since that time, process equipment has been changed to minimize the probability of a future release. Furthermore, the facility complies with the EPA's accident prevention rule and all applicable state and local codes and regulations. Our worst-case scenario is the unlikely failure of the sulfur dioxide pressure vessel during a time in which the maximum quantity is stored in it. The resulting distance to the endpoint extends offsite, and public receptors are within the distance to the endpoint. Our alternative release scenarios are piping breaks and small vessel leaks. The resulting distance to the endpoint extends offsite, and public receptors are withihn the distance to the endpoint. In the event of an emergency involving the release of sulfur dioxide, sulfur trioxide, or oleum across plant boundaries, it is our policy to notify the East Polk Sherrifs Office and Fire Department, the Fannin County Fire Department and Sherrifs Office, the Polk County LEPC, and TEMA. Due to the close proximity of the site location to the state borders of Georgia and North Carolina, TEMA and the Polk County LEPC may advise Intertrade to notify the North Carolina or Georgia LEPC. |