Springs Industries, Inc.- Grace Complex - Executive Summary |
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It has always been the policy of Springs for the Company and its subsidiaries to comply throughout the world with all laws and regulations involving environmental, safety and health matters. The Company is committed to continuous efforts to improve environmental, safety and health performance. This policy is embodied in the Springs of Achievement, especially the values of Planning for the Future and Personal and Family Well Being. This policy applies not only to Springs, but also to each of its subsidiaries worldwide. Facility Overview: The Springs Industries, Inc. facility in Lancaster, South Carolina, referred to as the Grace Complex, is a textile manufacturing and distribution facility producing printed, dyed, and finished fabric. The facility is regulated under RMP due to on-site chlorine and propane storage in excess of the RMP applicability threshold for each compound. Chlorine is used for water treatment which serves the purpose of treating process water used at the facil ity. Chlorine is stored in a railcar having a capacity of 110,000 pounds. Propane is used for onsite equipment as backup fuel in the case of natural gas curtailment. Several propane storage tanks exist at the plant with the largest tank storing 110,880 pounds. Chemical Safety Overview: The facility's overall approach and commitment to chemical safety is demonstrated by 1) the existing management, training, procedure and maintenance systems already in place at the facility, and 2) the hazard assessment, prevention program and emergency response provisions implemented specifically for chlorine and propane in response to the RMP requirements. The management structure and oversight to ensure safety is documented in the facility's RMP and includes compliance with applicable regulations, codes and standards (OSHA PSM Standard, US EPA 40 CFR 68 and NFPA guidance for propane). Release Scenarios: Worst-case and alternative release scenario assessments were conducted for the facility's s ingle largest vessel based on US EPA's Offsite Consequence Analysis guidance. The worst-case release scenario for chlorine is a 10-minute gaseous ground release of 110,000 pounds of chlorine and the alternate release scenario assumes a puncture in a supply line resulting in a release rate of 2,000 pounds per minute of chlorine. Public receptors were determined to be located within the impact zone of both the worst-case and alternative releases. The resulting worst-case and alternative release impact zones were 9.9 miles and 0.6 miles, respectively. The worst-case release scenario for propane is a vapor cloud explosion, causing the release of 110,880 pounds of propane and the alternate release scenario also assumes a vapor cloud explosion, resulting in the release of 84,260 pounds of propane. The resulting worst-case and alternative release impact zones were 0.4 miles and 0.2 miles, respectively. Public receptors were found within the impact zone of both scenarios. NFPA 58 guida nce on restricting the maximum propane inventory stored within a vessel to 88% (at 60 F) of the vessels rated capacity is followed at the facility to minimize the potential quantity released in an accident scenario. Five-Year Accident History: Due to our excellent accident release prevention programs, Springs has had no RMP reportable accidents/releases of chlorine or propane within the five years proceeding RMP submittal. Prevention Program: The facility has implemented a Program Level 3 Prevention Program for chlorine and a Program Level 2 Prevention Program for propane, as required by the RMP rule, in accordance with the US EPA guidance. These prevention program provisions are specifically intended to minimize the probability and/or consequence of any accidental chlorine or propane release from the facility and include such measures as process hazards analysis, operating procedures, training, contractors, pre-startup safety, mechanical integrity, hot work permit, management of change, incident investigation, emergency planning and response, and compliance audits. The facility prevention program is an ongoing system based on periodic training, incident investigations, audits, procedure revisions, and RMP updates as required to reflect facility change and RMP requirements. Emergency Response Program: The facility's Emergency Response Program has been perfected to produce the maximum effective response in the least amount of time. The facility has coordinated response with the Gooch's Cross Roads Fire Department and the Local Emergency Planning Committee (LEPC) to ensure that they will respond to any accidental release from the chlorine or propane system. The facility has also established a notification mechanism to ensure the fire department will be properly notified when any response is needed for a chlorine or propane release. Based on this coordination with the local emergency responders, the facility is not required to implement additional RMP emerge ncy response program requirements. Safety Management and Changes: The facility is committed to ensuring its operations are safe and in accordance with all RMP requirements, and has established a senior manager responsible for RMP development, implementation, and compliance. This manager is committed to maintain the safety of the RMP covered chlorine and propane systems through active adherence to the appropriate procedures and codes. To ensure that the appropriate changes occur as necessary to maintain/improve safety, ongoing hazard reviews, training, audits, maintenance and investigations will be conducted as required by RMP. Updates to the RMP will be completed as necessary in response to these activities. Summary: As documented in this submittal, the RMP for the facility has been completed in accordance with all 40 CFR 68 requirements and the facility has certified compliance. Springs takes pride in and is committed to conducting business in strict conformity with all applic able laws in a safe and responsible manner. The very highest priority is placed on the health and safety of Springs' associates and the community in which we conduct business. Springs has been a leader in the industry with environmental and health and safety programs, as exemplified by the numerous awards that Springs has been presented. These awards, such as Best Recycling Program for a Business and the Christopher Reeves Award for Environmental Leadership, recognize Springs' commitment to a variety of different areas. |