The Sherwin-Williams Company-Holland - Executive Summary |
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It is the policy of The Sherwin-Williams Company to conduct its business operation in such a manner as to protect the safety and health of our employees, our customers, the public and the environment. The safety and health of employees, customers, the public and the environment is of the highest priority to The Sherwin-Williams Company. We will implement programs which help to protect employees, customers, the public and the environment. We will comply with all applicable laws and regulations and implement programs to help ensure compliance. We will review all present and planned facilities, processes and products to ensure conformance with the applicable laws and regulations. We will manufacture products that can be used, handled, stored, distributed and disposed safely with common safety practices and The Sherwin-Williams Company's safety and health information. The Holland Plant packages aerosol products including paint, lubricants, adhesives, cleaners, disinfectants and air f resheners. Propane, butane, isobutane and methyl ether (i.e., propellants) are the RMP flammable substances used in the packaging of aerosols, and are stored on-site in excess of the threshold quantity. There are no listed toxic substances handled at this site in excess of the threshold quantity. The worst case scenario is a hypothetical release of any of the hazardous materials listed under the RMP rule as determined by the USEPA. The EPA mandates that companies presume the release of the entire quantity of the substance. Only passive safety controls, such as those controls in place that do not require action by an employee to initiate, can be considered. An example of a passive safety control is storage of a limited quantity (e.g., 85 percent maximum fill) in bulk storage tanks. The worst case scenario presumes none of the site's mechanical controls or safety systems requiring energy or human intervention are operational. The worst-case release scenario was determined by EPA t o be a vapor cloud explosion. The results were modeled using an EPA model, RMP*Comp. This scenario assumes that the total quantity of the flammable substance in the site's largest storage vessel is released into a vapor cloud, which then explodes. The endpoint for the impact zone was determined by EPA to be an overpressure level of 1 pound per square inch (psi) from the explosion of the vapor cloud. The modeling for the Holland Plant assumed a release of 67,626 pounds of propellant from the largest storage tank, which is 85 percent of the maximum fill capacity. It resulted in an endpoint of 0.33 miles. However, these results are very conservative. EPA's own guidance indicates that EPA considers not only the release of the total quantity of a flammable substance in a vessel into a vapor cloud to be highly unlikely, but also the explosion of a vapor cloud to be an unlikely event. Further, the guidance states that the endpoint of 1 pound per square inch is intended to be conservati ve and protective, and does not define a level at which severe injuries of death would be commonly expected. The alternative release scenario is considered to be more realistic. The alternative case assumes the release of the total quantity of a tank, 67,626 pounds, from the largest storage tank and a jet fire develops. This is 85 percent of the maximum fill capacity. This scenario was modeled with the PHAST model. The alternate case assumes a 3-inch pipe from the railcar breaks. Ignition occurs at the LEL distance, resulting in a pool fire. If the railcar is not damaged, a jet flame develops from the broken pipe. The endpoint of 5 kW/m2 was used, and was determined to be 0.05 miles (i.e., 288 feet). Receptor and population impacts were estimated using LandView III and the most recent U.S. Census data. This data is an average for the area in which the plant and the worst case impact zone are located. These results are approximate and appear to be conservatively high based upon a review of the topographic maps for the area surrounding the plant. The following safety prevention and emergency response steps are also in place to further reduce the likelihood of any effect on the community in the event of the alternative case release scenario: operator training and certification programs; technical staff training and support; process hazard analysis; mechanical work plan analysis; equipment integrity standards; mechanical integrity inspections; management of change; safety audits; emergency shutdown systems; emergency procedures; and, accident investigations. There has not been an accident or incident that has met the RMP criteria involving propane, butane, isobutane or methyl ether at the Holland plant during the last five years. Criteria for RMP reporting are accidents that have resulted in death, injury, significant property damage, evacuation, sheltering in place, or environmental damage. The plant, in its 31-year history, has never had a release that ca used off-site injury. The Holland Plant maintains trained responders to handle a variety of emergencies at the site including incipient fires, chemical spills, and tornadoes. The site has also made arrangement for assistance from the local fire department and emergency responders as well as third party contractors to respond to incidents of a larger scale. The site has continually reviews, and if necessary improves, the safety programs and systems at the facility. For example, the Holland Plant is planning to install improved ventilation systems in the propellant filling rooms to reduce the likelihood that an explosive mixture could accumulate in the process. The site is also installing a water deluge system for the bulk propellant storage areas that will operate in the event of a fire. |