Progress Casting, Inc. - Executive Summary

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1.0    Executive Summary 
Progress Casting in Plymouth, Minnesota (Progress) is subject to Risk Management Planning requirements of 40 CFR Part 68 due to storage of Sulfur dioxide (SO2) and Liquid Propane Gas (LPG)  at its facility.  Due to the stay on propane, the following submitted data elements do not address the LPG storage.  Progress has one 2000 pound cylinder of SO2, which is used for curing in the core making process for the manufacturing of aluminum castings.  A Risk Management Plan (RMP) is required because the storage quantity of SO2, a toxic substance, is subject to Process Safety Management (PSM) and exceeds 1,000 pounds in a single process. 
This RMP needs to meet Program 3 requirements, because the process has the potential to impact off-site receptors resulting from a worst-case release scenario.  The RMP requires the Data Elements Submission, an Offsite Consequence Analysis, a Program 3 Prevention Program, and an Emergency Response Plan.  
1.1    Company Policy 
Progress has  
developed corporate policies for enhancement of employee health and safety and environmental management programs.  Progress is strongly committed to employee, public, and environmental safety.  Each individual employee is responsible for observing all safety regulations and practicing good safety at all times.  No job is too important to not take the time to perform the work safely.  No operation shall be carried out until safety is assured.  The Progress - Plymouth foundry is audited by corporate personnel on an annual basis to ensure continued enhancement of its health and safety and environmental programs. 
1.2    Stationary Source Information 
Progress is subject to Program 3 RMP requirements, because the SO2 storage is above the PSM threshold quantity and the worst-case release scenario could impact off-site receptors.  Thus, an alternative release scenario was also performed.  However, the alternative release scenario is not expected to significantly impact off-site receptors. 
1.3    Off 
-Site Consequence Analysis 
The worst-case release scenario would occur from the sudden release of the entire contents of one, 2,000 pound SO2 tank resulting in a toxic gas release.  The alternative release scenario was determined for a pipe rupture release.  The distances to the toxic endpoint for the worst-case release scenario and the alternative release scenario were 0.9 mile and 0.2 mile respectively.   
1.4    Accidental Release Prevention Program 
Progress has taken all necessary steps to comply with the accidental release prevention requirements set forth under 40 CFR Part 68.  Progress has developed the required elements of a Program 3 prevention program, including Safety Information, Hazard Review, Operating Procedures, Training, Maintenance, Compliance Audit, and Incident Investigation programs.  In addition, Progress has prepared an Emergency Response Plan designed for timely, safe, and efficient response to minimize hazards to human health and safety.  The plan is reviewed and u 
pdated periodically to ensure that the information is accurate. 
1.5    Five-Year Accident History 
Within the previous five years, Progress had one (1) accidental release of SO2, which is a regulated substance that caused injuries or the need for response or restoration activities.  It was responded to quickly by trained on-site personnel and the injured employees were treated in the hospital and released.  The cause of the release was repaired without further incident.  No off-site response was deemed necessary as a result of the release.   
1.6    Emergency Response Program 
Progress has written Emergency Plans and Procedures to deal with accidental releases of hazardous materials.  The plan includes all aspects of emergency response actions including adequate first aid and medical treatment, evacuations, notification of local emergency responders, as well as post-incident clean-up and decontamination of affected areas.   
The Emergency Plans and Procedures for Progress was last updated in Ma 
y 1999.  Progress also has a Hazardous Waste Contingency plan to prevent and control the accidental release of hazardous waste material from this facility. 
1.7    Safety Improvements Planned 
Progress will make any necessary improvements for the SO2 storage system identified through its annual maintenance check as well as the inspections prior to each use.  Progress may set up contracts with its supplier and/or qualified service companies to conduct the annual inspection and servicing the SO2 system. 
1.8    General Duty Clause 
The RMP regulations include a general duty clause to prevent release of any hazardous material regardless of quantity stored on-site. Other than propane, the chemical storage areas at Progress include enclosed designated chemical storage areas at a few areas within the building. The risk of releases from chemical storage areas at Progress is low due to inherent safeguards, proper handling procedures and employee training.  Thus, these activities were not included in the 
off-site consequence analysis for this facility.  Propane was included in this plan to comply with the General Duty Clause in light of the propane RMP deadline stay.  If propane is determined to be included as a 112(r) regulated substance, Progress will submit the required RMP*Submit for that chemical prior to the submission deadline.   
2.0    Data Elements 
Progress has completed the required data elements information required for RMP submission to the U.S. Environmental Protection Agency (USEPA).  A diskette and printout of the data elements submission report is contained in Appendix A.   
3.0    Off-Site Consequence Analysis 
The Off-site Consequence Analysis (OCA) for Progress's RMP includes a worst-case release scenario and an alternative release scenario.  Appendix B includes calculations for the quantity of propane released for each scenario, and a diagram showing distances to the flammable endpoint resulting from the worst-case and alternative release scenarios. 
3.1    Worst-Case Relea 
se Scenario 
The worst-case release scenario was used to determine the greatest distance to the toxic end-point caused by sudden release of the entire contents of the largest SO2 tank.  For this analysis, the toxic material endpoint would be a 0.9 mile radius caused by sudden release of one, 2,000 pound SO2 tank resulting in a liquid spill and vaporization. RMP*Comp was used for this release scenario, which is a U.S. EPA program for determination of the distances to flammable or toxic endpoints.  The SO2 tank is located inside a building, which was considered for purposes of this analysis.    
Progress is located in a urban and industrial area.  Thus, a limited amount of residential areas could be impacted by a worst-case release scenario.   Based on a map showing population densities in the Plymouth area (1990 census data), the number of persons within the area impacted by a worst-case release scenario would be fewer than 4,800 persons.   No schools, hospitals, or environmental recepto 
rs are within 0.9 mile radius of the source.    
3.2    Alternative Release Scenario 
The alternative release scenario was used to determine the distance to the toxic end-point caused by a more likely event than the worst-case release scenario.   For this analysis, the toxic material endpoint would be caused by a sudden release of contents from tank as the result of the safety sled valve being sheared off the tank which would result in a liquid spill with vaporization. It was assumed for the alternative release scenario that a pipe rupture release would more likely occur than a tank release due to inherent safety features of the SO2 storage tanks.  Since the SO2 tank is stored and used indoors, the enclosure was considered for purposes of this analysis.   
Using RMP*Comp, the alternative release scenario could cause an area of impact within 0.2 mile in radius.  The only off-site receptors located within a 0.2 mile radius of the source would be nearby industrial buildings.  The estimated pop 
ulation affected by the alternative release scenario would be less than 100 persons.   
4.0    Prevention Program 
Progress has prepared a Program 3 prevention program according to the RMP rule.  The prevention program for Progress includes seven program elements: safety information, hazard review; operating procedures, training, maintenance, compliance audit, and incident investigation described below. 
4.1    Safety Information 
The safety information for the SO2 storage system includes: (1) a material safety data sheet (MSDS); (2) the maximum intended inventory of SO2 on site; (3) safe and upper and lower temperatures, pressures, flows, and compositions; (4) equipment specifications; (5) codes and standards used to design, build, and operate the process.  A MSDS for SO2, Piping & Instrumentation Diagrams (P&ID's), and safety information for the SO2 storage system at Progress is included in Appendix C.  The maximum intended inventory is 2,000 pounds.  The empty tank is filled off-site and exc 
hanged on-site with a full tank.  The SO2 system is connected to a safety sled, which detects pressure changes in the lines and will automatically shut down the system to prevent additional releases.   
Progress has compiled safety information for its SO2 storage system.  A process safety hazard analysis has also been conducted for this system.   
The safety information will be updated as needed when major changes are made to the system or every five years.  Major modifications or changes for the SO2 storage system will be documented using a table for major changes included in Appendix C.   
4.2    Hazard Review 
The hazard review requires Progress to identify the hazards associated with the process, opportunities for equipment malfunctions or human errors that could cause an accidental release, the safeguards used or needed to control the hazards or prevent equipment malfunctions, and any steps used or needed to detect or monitor releases.  A process safety hazard analysis was conducted fo 
r the SO2 and is included in Appendix L.   
The hazard review needs to be updated at least every five years or whenever a major change is made to the system.  All issues identified in the updated hazard review need to be resolved before startup of the changed process.   
4.3    Operating Procedures 
The RMP requires written operating procedures to provide clear instructions for conducting activities consistent with the safety information for the process.  Operating procedures include training requirements and safety and health considerations. 
Only qualified Progress personnel or contractors will be permitted to perform annual maintenance checks of the system.  Personnel performing maintenance or equipment changes on the SO2 storage system shall be adequately trained to understand and avoid the hazards associated with SO2. Operating procedure guidelines are included in Appendix C. 
4.4    Training 
Annual training will be provided for all employees to assure understanding of procedures and to ac 
quaint new staff with plant chemical and safety hazards and emergency response procedures.  New staff will have these procedures explained to them during their initial operator and safety training. In particular, supervisors and managers will be instructed in the hazards and regulations associated with hazardous materials and the necessary procedures to prevent and control spills and releases.  Documentation of training will be retained with employee training records. 
4.5    Maintenance  
Inspection, testing, and servicing of the SO2 system will be conducted annually by trained personnel.  The main focus of annual maintenance is to ensure the system operates properly throughout the year.  Inspections prior to use on a daily basis is also conducted.  Maintenance personnel shall look for evidence of: 
* deterioration or corrosion which could threaten the integrity of the equipment 
* damage, such as dents or cracks, which could threaten the integrity of the equipment 
* gas leaks from valves  
and other fittings 
* malfunction of pumps, valves, the vaporizer, instrumentation, and safety equipment 
Inspections of the system will be documented on an inspection form and retained for at least five years.   
4.6    Compliance Audits     
Progress shall conduct a compliance audit of the SO2 storage system and certify that they have evaluated compliance with RMP provisions at least once every three (3) years.  The intent of the audit program is to determine the effectiveness of the RMP and to identify any deficiencies that could lead to a release.  The compliance audit will be conducted to check each element of the RMP program.  In addition, the RMP will be amended in accordance with the guidelines and regulations whenever there is a change in the facility which affects the potential for releases to occur.  These changes would include addition or deletion of tanks, equipment, or piping.  
At least one member of the audit team will need to be knowledgeable about the process.  Progress will 
 prepare a written report of the compliance audit findings and retain the two (2) most recent reports on file.  These records shall be retained for at least five (5) years after the audit was conducted.  An compliance audit procedure and checklist is included in Appendix J.    
4.7    Incident Investigation 
Progress understands the importance of an incident investigation to determine the root cause of an incident.  Identifying the root causes of an incident will help to reduce and prevent injuries associated with a release of SO2.  In addition to any actual release, Progress will investigate near releases involving the SO2 storage system.  In the event of a release or near release, Progress will assemble an investigation team as soon as possible to determine the root cause associated with the incident.  Outside contractors will be involved if they were associated with an incident.  An incident investigation checklist is included in Appendix K.  
5.0    Emergency Response Program 
Progress ha 
s developed a comprehensive emergency response program to deal with plant emergencies.  The Emergency Action Plan details programs developed for medical, severe weather, plant evacuation, fire, chemical release, and bomb threat emergencies.   
The local community response agency is the City of Plymouth Fire Department.  In the event of a chemical release, they will be immediately contacted for assistance.  Additional resources are also available from nearby communities as well as the Minnesota Emergency Response Commission.   
6.0    Summary of Periodic Compliance Requirements 
A summary of periodic compliance requirements for Progress's RMP program is shown in Table 1 below. 
Table 1 
Summary of Periodic Compliance Requirements 
Program Element 
Frequency of Review 
or Updates 
Date of Previous Review 
or Updates 
Data Elements 
Major changes or every 5 years 
Off-Site Consequence Analysis 
Major changes or every 5 years 
Safety Information 
Major changes 
Hazard Review 
Major changes or ev 
ery 5 years 
Operating Procedures 
Major change or as needed 
Compliance Audit 
Every 3 years 
Incident Investigation 
As needed 
Emergency Response Plan 
As needed 
Progress will perform the required review and updates as required in the RMP rule.  A copy of the RMP regulation is included in Appendix J. 
7.0    Community Relations and Public Information 
In conformance with 40 CFR 68, Progress has prepared this RMP as part of its ongoing commitment to protect health and safety of employees and the public.  It is the goal of Progress to develop and build a relationship with the community and build trust among the public, neighbors, and the community at large. 
As part of its company objectives, Progress intends to take its place as a good citizen in the community.  Progress believes that the Company and each individual employee have a responsibility to the communities where they work and live.  In this regard, Progress encourages employ 
ee involvement in the community, and both employee and Company support of local charitable organizations.  Finally, Progress and community both have an interest to maintain an atmosphere of open relations.   
This section is intended to answer commonly asked questions about this RMP for Progress. 
Frequently asked questions: 
What is the difference between hazard and risk? 
Hazards are inherent properties that cannot be changed.  Sulfur dioxide (SO2) is toxic and can lead to a respiratory irritation if released in sufficient quantities.  SO2 is a gas at ambient conditions.  Therefore, it is normally stored as a pressurized liquid.  Being heavier that air, it can collect in low places and displace oxygen.  There is nothing that can be done to change the properties of SO2. Another example of hazard is from the natural causes, such as severe weather, floods or earthquakes.  
Risk is usually evaluated based on several variables, including the likelihood of the release occurring, the inherent 
hazards of the chemical and the quantity released, and the potential impact of the release on the public and the environment.  For example, if a release occurs during loading and the quantity of release is small and does not migrate offsite, the overall risk to the public is low.  If the likelihood of a catastrophic release is extremely low, but the number of people who could be affected is large, the overall risk may still be low because of the low probability that a release will occur.   
What does the Worst-Case Release Distance Mean? 
The worst case distance is intended to provide an estimate of the maximum possible area that might be affected under catastrophic conditions.  It is intended to ensure that no potential risks to public health are overlooked, but the distance to an endpoint under worst-case conditions should not be considered a "public danger zone".  In most cases, the models used to determine the extent of a worst-case release scenario may overestimate the area that w 
ould be impacted by a release.  For great distances from the site, the models are especially uncertain.  The models do not incorporate site-specific factors, such as buildings or berms located between the source and the public.  These obstacles could mitigate and reduce the area of impact, if a worst-case release should occur. 
If there is an accident, will everyone within 0.9 miles be hurt? 
In general, no.  For a flammable release, everyone with the circle would certainly feel the blast wave since it would move in all directions at once.  However, while some people within the circle could be hurt, it is unlikely that everyone would be since some people would probably be in less vulnerable locations.  Most injuries would probably be due to flying glass, falling debris, or impact with nearby objects.  Generally, it is the people closest to the facility who would face the greatest danger if an accident occurred.  In an explosion, environmental impacts and property damage may extend beyon 
d the distances at which injuries could occur.  
For toxic chemicals, whether someone is hurt by a release depends on many factors.  First, the released chemicals would usually move in the direction of the wind (except for some dense gases, which may be constrained by terrain features to flow in a different direction).  Generally, only people downwind from the facility would be at risk of exposure if a release occurred, and this is normally only a part of the population inside the circle.  If the wind speed is moderate, the chemicals would disperse quickly, and people would be exposed to lower levels of the chemical.  If the release is stopped quickly, they might be exposed for a very short period of time, which is less likely to cause injury.  However, if the wind speed is low or the release continues for a long time, exposure levels will be higher and more dangerous.  The population at risk would be a larger proportion of the total population inside the circle.   
Generally, it is th 
e people who are closest to the facility who would face the greatest danger is an accident occurred.  Damage to property and the environment will depend on the type of chemical released.  In an explosion, environmental impacts and property damage may extend beyond the distance at which injuries could occur.  For a vapor release, environmental effects and property damage may occur as a result of the reactivity or corrosivity of the chemical or toxic contamination.  
(Exerpt from the Risk Management Program Guidance for Wastewater Treatment Plants)  
How sure are you of your distances? 
The distances determined in this RMP were based on conservative estimates which would tend to overestimate the impact area from a catastrophic release.  The model represents scientist's best efforts to account for all variables involved in an accidental release.  No model is perfect and different models can produce differing results.  Progress has used the guidance established by EPA (EPA Lookup Tables) to 
represent a worst case situation for a propane release.  Progress believes that using a conservative approach yields conservative (overestimate) results for the distances that would occur from a worst-case release.  Progress recognizes that within the predicted distance is a band of uncertainty, and in the unlikely event of a catastrophic release, the extent of impact may be shorter or longer depending upon the conditions at the time of release.  
Do you need to store 36,000 gallons of propane? 
Progress has determined that storing propane in two, 18,000 gallons tanks is sufficient to supply fuel for short periods of time during curtailment periods.  For most of the time, Progress relies on natural gas from a pipeline to provide comfort heat inside its facility.  However, during periods of high demand, the local utility company requests that the users of large volumes of fuel to switch to alternate fuel.  These curtailment periods usually occur during the coldest parts of winter.  The  
amount of propane stored at Progress is sufficient for only a few days of operation during very cold weather periods.  Thus, the amount of propane stored is enough to continue operation during temporary curtailment periods. 
What are you doing to prevent releases? 
Progress believes that the safety of its employees and community are of primary importance.  Progress is committed to developing and implementing safe work practices and procedures, and to maintain equipment in a safe condition.  Progress is also committed to providing training to employees to enable then to work and prevent accidents from occurring.  Employees are trained and instructed to comply with all safety rules, regulations, and procedures. 
In addition to proper training of employees, supervisors and managers are responsible for managing emergency response actions and procedures.  Supervisors and managers will be accountable for actively supporting and participating in the RMP program, including communication of, co 
mpliance with, and monitoring of safety performance. 
What are you doing to prepare for releases? 
Progress believes that it is important to prevent releases through proper procedures and handling of propane.  In the event of a release, Progress has developed procedures and contingencies to respond.  Employees have been trained to properly respond to releases of SO2 and propane, to protect themselves, other employees, and the public.   
In the event of a release that is beyond the control, or presents and unacceptable risk to employees, the City of Plymouth Fire Department may respond to the emergency.  The Plymouth Fire Department will implement their incident command system to manage the emergency response and request additional assistance, if necessary. 
How likely are the worst-case and alternative release scenarios? 
It is generally not possible to provide accurate numerical estimates of how likely these scenarios are.  EPA has stated that providing such numbers for accident scenari 
os rarely is feasible because the data needed (e.g. rates for equipment failure and human error) are not usually available.  Even when data are available, there are large uncertainties in applying the data because each facility's situation is unique. 
In general, the worst-case scenario is low.  Although catastrophic vessel failures have occurred, they are rare events.  The alternative scenario, although more likely, is also believed to occur very rarely.  Progress is committed to developing and maintaining safe work practices and procedures, to maintain equipment in a safe condition.  Progress is also committed to providing training to employees to enable then to work and prevent accidents from occurring.  Employees are trained and instructed to comply with all safety rules, regulations, and procedures.  As evidence of Progress's committed adherence to safe work practices and procedures, the propane storage system has not experienced a reportable release or incident since Progress obt 
ained ownership of the site in 1985. 
Is the worst-case release scenario you reported really the worst accident you can have? 
EPA defined a specific scenario (failure or the single largest vessel) to provide a common basis of comparison among facilities nationwide.  Progress stores two, 18,000 gallon pressurized propane tanks.  The absolute worst scenario would occur if the entire contents of both tanks were released simultaneously resulting in an explosion.  In this case, the distance to an overpressure endpoint of 1 psia would be 0.5 mile based on EPA's Lookup Tables.  It should be noted that the relationship between the quantity of flammables released and the distance to the endpoint are not directly proportional.  Thus, doubling the release quantity does not double the distance to the endpoint.  Progress has determined that such a release would be extremely unlikely and the worst-case release from a single vessel was appropriate.  
An event that may result in the complete release o 
f propane from multiple vessels would most likely involve a disaster, such as a tornado, that completely destroys the facility.  If this occurred, the effects of the natural disaster would make modeling the release nearly impossible and certainly very inaccurate.  In this case, the primary and secondary effects of a tornado and response requirements to the citizens in the area would be the primary concern. 
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