Greenville Tube Corporation - Executive Summary
GREENVILLE TUBE CORPORATION |
RISK MANAGMENT PLAN
1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES.
At this Greenville Tube Corp., we utilize anhydrous ammonia which is considered hazardous by the Environmental Protection Agency (EPA). The properties which make ammonia valuable in manufacturing also necessitate certain safety precautions. Greenville Tube Corp. strives to protect all its valuable resources and assets - both personnel and property. We live and have families in this community. We want to prevent exposure to all our personnel as well as nearby members of our community, existing natural resources, and the surrounding environment. It is our policy to comply with all Federal, State, and Local regulations. Through continual, accurate training and various safety devices and procedures, we work to minimize potential releases.
Our emergency response program has specific procedures for accidental releases of anhydr
ous ammonia as well as other emergencies. We work in conjunction with the Clarksville Fire Department and the Local Emergency Planning Committee to prepare for necessary notification of all affected neighbors.
2. THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED.
The primary purpose of our facility is the production and manufacturing of stainless steel pipe. We utilize anhydrous ammonia in the manufacturing process. An outside company is used to fill our main receiver tanks. Piping then carries the ammonia to the needed areas for dissassociation. Access to the site is restricted to facility employees, authorized management personnel and authorized contractors.
The regulated substance used at our facility is anhydrous ammonia. The maximum amount of ammonia stored at this facility is 11,200 pounds. We have the capacity for 14,000 pounds but our policy is not to exceed ammonia recommendations of 80%.
3. THE WORST CASE RELEASE SCENARIO(S) AND THE ALTERNATIVE RELEASE SC
ENARIO(S), INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCES FOR EACH REPORTED SCENARIO.
Worst Case Scenario
The worst case scenario would be failure of our largest receiver. Our policy restricts the maximum capacity of this 40,174 pound tank to 80% of capacity. The amount stored in that tank is 32,238 pounds. It is assumed that the entire contents are released as a two phase flow (gas and aerosol-ALOHA).
Distance to endpoint: 2.3 miles
The alternative scenario would be the release of ammonia due to the failure of a pressure relief valve. The emergency alarms would signal monitoring personnel to notify a technician to take action. The maximum time of the release would be 60 minutes and maximum quantity released would be approximately 3,085 pounds of ammonia.
Distance to endpoint: 0.14 miles (or 254 yards)
4. FIVE-YEAR ACCIDENT HISTORY.
To date, this Greenville Tube Corp. facility has not incurred a reportable release.
5. THE RMP MANAGEMENT PROGRAM.
The management of the RMP program will be handled by Mr. Rusty Griffin, Industrial Hygiene Specialist. Mr. Griffin will administrate in conjunction with the Greenville Tube Corp. management and personnel. Other entities or organizations that will be coordinated with include the Johnson County Local Emergency Planning Committee and the Clarksville Fire Department.
6. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE SPECIFIC PREVENTION STEPS.
The Greenville Tube Corp. facility complies with all applicable Federal, State and Local regulations including the EPAs Accidental Release Prevention Rule. Our personnel are trained about this during our Hazard Communications Training and through access to our Written Programs. Our Ammonia operators receive classroom training. They are given written tests to determine proper job skills and knowledge. Also, the ammonia system is operated, tested and maintained to industry standards.
7. THE EMER
GENCY RESPONSE PROGRAM.
We work very closely with the Local Emergency Planning Committee and the Clarksville Fire Department and HAZMAT team on emergency preparedness. We meet periodically with representatives of each to address any changes in the facility or any new concerns.
8. PLANNED CHANGES TO IMPROVE SAFETY.
Currently, Greenville Tube Corp. trains and tests all ammonia technicians. Our preventative maintenance program is above standard and our total ammonia Process Safety Program is reviewed annually and updated periodically. Our program is improved continuously through annual updates of our written program and annual training of our technicians. We also take advantage of new technologies when safer and more economical alternatives are available.