Penn Champ Inc. - Executive Summary |
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Penn Champ Inc. is located in East Butler, Pennsylvania, at the corner of Railroad & Lincoln Avenues, approximately 2 miles northeast of the town of Butler, Pennsylvania. Penn Champ is a subsidiary of the Bissell Specialty Chemical Corporation. For more than 60 years, we have grown our reputation in the private label aerosol and liquid household, health and beauty, and automotive products industries by providing the highest quality products and the best customer service. Our in-house staff of chemists have created formulations that perform equal to, or better than their "brand name" national counterparts. Our chemists use their combined 40 plus years of experience to create a product to meet the highest performance standards. A major part of that performance criteria is creating products that are environmentally friendly. At Penn Champ Inc. we use no chlorofluorocarbons (CFC's) and meet or exceed standards issued by the U.S. Environmental Protection Agency (USEPA). We are proud of our facility and the stability of our workforce. The Federal Accidental Release Prevention Requirements under the Clean Air Act Section 112(r) ("112(r)"), codified in 40 CFR Part 68, were written to help prevent the accidental release of extremely hazardous substances and to minimize the consequences of any such release. All facilities with threshold quantities (TQs) of the listed regulated acutely toxic and flammable substances are subject to these provisions. The listed substances include 77 toxic chemicals with TQs ranging from 500 lbs. to 20,000 lbs., while the 63 flammable substances all have a TQ of 10,000 lbs. Penn Champ has two mixtures of flammable substances that meet the criteria for listing under 112(r), and thus, these substances must be included in a Risk Management Program for the respective operation. These substances, whose major components are propane and isobutane, are propellants stored in bulk vessels and used in the process of individual canisters. For each of these substances, Penn Champ must comply with the following major requirements of Section 112(r) of the Clean Air Act : - Management System development and documentation, - Hazard Assessment for each affected process, - Prevention Program completion, - Emergency Response Program coordination, and - Risk Management Plan submittal. In addition, Penn Champ recognizes its responsibility under Section 112(r)(1) (the "general duty clause") to safely handle all Extremely Hazardous Substances (regardless of their quantities) to prevent their accidental release and to minimize the consequences of any such release. Additional chemicals on site, not meeting their TQ or not identified in the 112(r) list rule, are managed using risk-management principles similiar to those applied to our chemicals fully covered by 112(r). This Executive Summary of Penn Champ's Risk Management Plan (RMP) provides an overview of how we are effectively meeting our responsibilities t o the community through compliance with the 112(r) rule. MANAGEMENT SYSTEM Penn Champ has established a management system to oversee the implementation of its Risk Management Program responsibilities. The management system is designed to help ensure that each element of our program is fully and effectively completed. A qualified person has been assigned overall responsibility for the development, implementation, and integration of the program elements. Responsibility for implementing individual requirements of the Treatment Plant's program have been delegated to competent individuals. An organization chart has been prepared to identify the responsible personnel and lines of authority for implementing the program. Record-keeping responsibilities are also included in the management system. HAZARD ASSESSMENT The Hazard Assessment portion of the 112(r) rule requires facility owners or operators to prepare "worst-case" and "alternative" release scenarios as appropriate to the opera tions. From the release scenarios, facilities are then to determine offsite impacts using specified "Offsite Consequence Analysis" (OCA) parameters for worst-case releases and more realistic parameters for alternative releases. As defined by the U.S. Environmental Protection Agency (EPA): - The worst-case release involves the release of the largest quantity of a listed flammable substance that is estimated to generate the greatest distance in any direction to a 1 pound per square inch (psi) overpressure as defined in the 112(r) regulation. The probability that a worst-case release might occur or the possible causes of such a release are not considered. - The alternative scenario involves an accidental release that is "more likely to occur" than the worst- case release scenario. Scenarios to consider include transfer hose splits or uncoupling, process piping failures, process vessel or pump cracks and failures, vessel overfilling and spill or overpressurization and venting through relief valves or rupture disks, and shipping container mishandling and breakage or puncturing leading to a spill. Worst-Case Release Scenario: - We assumed a complete rupture and content loss of the largest quantity vessel. The rupture results in a vapor cloud explosion. As required by the regulation, a 1 psi overpressure criteria was used in estimating the endpoint distance. Alternative Release Scenario: - We assumed a process piping shear and content loss of 10,600 gallons. An operator is assumed to isolate the system in 5 minutes. The scenario assumes a two-phase release. The rupture results in a vapor cloud exposion. A 1 psi overpressure endpoint was used in estimating the endpoint distance. The OCA of each potential chemical release was analyzed using appropriate air dispersion analysis and modeling techniques. Air dispersion modeling is the use of a computer to simulat e the spread of air pollutants. Dispersion modeling can be used to determine the movement and concentration of toxic and flammable gases emitted from an accidental release. To determine the OCA of worst-case and alternative flammable releases, Penn Champ used the most-recent version of several air dispersion models and modeling techniques, as follows: ARCHIE (Automated Resource for Chemical Hazard Incident Evaluation) flammable-gas model (prepared by the Federal Emergency Management Agency, U.S. Department of Transportation, and the U.S. Environmental Protection Agency's (EPA)) estimates downwind dispersion of a chemical release and is especially useful for analysis of explosions and fires. EPA Document 550-8-98-011, is the EPA's Risk Management Program Guidance for Propane Storage Facilities (40 CFR Part 68). This document was developed for the propane storage industry and provides guidance on the estimates of potential release scenarios a nd the calculation of release quantities and endpoints. EPA OCA Guide, is the EPA's Offsite Consequence Analysis Guidance (May 1996) that provides rough estimates of offsite impacts from evaporating pools of chemicals and vapor cloud explosions. RMP*Comp software is based on the U.S. Environmental Protection Agency's (EPA's) RMP Offsite Consequence Analysis Guidance (May 1996): that provides rough estimates of offsite impacts from evaporating pools of chemicals and vapor clouds. The estimated population within the worst-case release circle is 1,000, while the estimated population within the alternative release circle is estimated at 900. Modeling Limitations and Assumptions Air-dispersion models are limited in their ability to accurately predict the impact of a chemical release. Their limitations increase as the complexity of the topography surrounding the release site increases. PREVENTION PROGRAM The Prevention Program helps to e nsure that regulated substances are safely stored, used, and handled. In addition, if a chemical release occurs, the Prevention Program ensures that procedures and equipment are established to detect and mitigate the impact of such a release. Safeguarding the public from accidental releases through an effective Prevention Program is an important component of the 112(r) rule. Penn Champ has fulfilled the Program 2 Prevention Program requirements for safety information, hazard review, operating procedures, employee training, maintenance program, compliance audits and incident investigation. FIVE YEAR ACCIDENT HISTORY For at least the past five years, no accidental releases from covered processes have occurred that resulted in deaths, injuries, or significant property damage onsite, or known offsite, deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. EMERGENCY RESPONSE PROGRAM An Emergency Response Program has been developed and implement ed for the purpose of protecting public health and the environment. PLANNED CHANGES TO IMPROVE SAFETY Penn Champ has recently evaluated its safety systems. We will continue to explore various measures to protect the community and the environment from accidental releases. |